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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 protection authority (DPA)

A data protection authority (DPA) is the independent public authority established by each EU or EEA Member State to monitor and enforce the application of the GDPR and national data protection law. The GDPR calls it a supervisory authority (Art. 51); familiar examples are the CNIL (France), the ICO (United Kingdom, under the UK GDPR), the AEPD (Spain), the Garante (Italy), the Irish DPC and Germany's federal and Länder authorities. Switzerland's equivalent is the FDPIC under the FADP.

DPAs have investigative powers (audits, access to premises and data), corrective powers (warnings, reprimands, orders to comply, bans on processing, suspension of transfers) and the power to impose administrative fines of up to EUR 20 million or 4% of worldwide annual turnover (Art. 58 and 83). They also handle complaints, approve BCRs and codes of conduct, and publish guidance; several DPAs (CNIL, Garante, Datatilsynet) have issued specific guidance or reference methodologies for health research.

Life sciences companies interact with DPAs when notifying a personal data breach within 72 hours, when consulting prior to high-risk processing under Art. 36, when a data subject complains, and during inspections. A non-EU sponsor deals with DPAs through its Data Protection Representative; an EU-established group deals primarily with the authority of its main establishment under the one-stop-shop.

Is a data protection authority the same as a company’s DPO?

No. A data protection authority is an independent public regulator with supervisory and enforcement functions. A data protection officer advises and monitors within an organisation’s governance arrangements. Keep the roles separate when assigning responsibility for complaints, regulatory correspondence and internal advice; appointing a DPO does not replace the authority’s oversight.