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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 retention

Data retention refers to the rules and practices governing how long personal data is kept before it is deleted or anonymised. Under the GDPR the governing principle is storage limitation (Art. 5(1)(e)): data must be kept in identifiable form no longer than necessary for the purposes for which it is processed, with longer retention permitted for archiving in the public interest, scientific or historical research or statistical purposes, subject to appropriate safeguards (Art. 89).

Sector legislation sets specific minimums. Art. 58 of the EU Clinical Trials Regulation 536/2014 requires the sponsor and the investigator to archive the clinical trial master file for at least 25 years after the end of the trial, while subjects' medical files are kept according to national law. The MDR requires technical documentation to be kept for 10 years (15 for implantables) after the last device is placed on the market; pharmacovigilance records are kept for the life of the product plus 10 years; and HIPAA and national health laws add their own periods.

A retention schedule is therefore not a single number but a matrix of data categories, legal bases and periods, documented in the record of processing activities and communicated in information notices. Retention periods also drive vendor contracts, backup configurations and the moment at which a data subject's erasure request can be honoured. Indefinite retention "just in case" is one of the most frequent findings in gap analyses.