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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.

F

Filing system

A filing system means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis (Art. 4(6) GDPR).

The concept determines the material scope of the GDPR for non-automated processing. Under Art. 2(1), the Regulation applies to the processing of personal data wholly or partly by automated means, and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of one. Paper medical records organised by patient, paper informed consent forms filed by subject number, investigator site files and archived case report forms are therefore within scope, even though no computer is involved. The Court of Justice (Jehovan todistajat, C-25/17) confirmed that the structure need not be sophisticated: handwritten notes organised so that a specific person's data can be retrieved suffice.

In clinical research the practical consequences are that paper archives must be protected by security measures proportionate to the risk (locked rooms, access logs, secure destruction), included in the record of processing activities, covered by retention schedules, and searchable enough to honour a right of access request. Unstructured notes that are not organised for retrieval fall outside the definition, but few research records genuinely meet that description.