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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 subject

A data subject is the identified or identifiable natural person to whom personal data relates (Art. 4(1) GDPR). A person is identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity. Only living natural persons qualify; legal persons and, in most Member States, deceased persons do not.

The data subject is the holder of the rights set out in Chapter III of the GDPR: information, access, rectification, erasure, restriction, portability, objection and protection against solely automated decisions. These rights must be facilitated by the controller, generally free of charge and within one month.

In a clinical trial the data subjects are not only the participants but also investigators, site staff, legally designated representatives, caregivers providing observer-reported outcomes, and sponsor and vendor staff whose data appears in audit trails. Each group needs an appropriate information notice. Trial participants remain data subjects even though their data is pseudonymised, and some of their rights (notably erasure) are limited by the research safeguards of Art. 89 and by regulatory retention obligations.

Are trial participants the only data subjects in a study?

No. Investigators, site staff, caregivers and other people can also be data subjects when information relates to them. For example, a caregiver diary may contain information about both the participant and the caregiver. Identify these groups during study setup and provide information and rights-handling arrangements appropriate to each group.