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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.

G

Good clinical practice (GCP)

Good clinical practice (GCP) is a set of detailed ethical and scientific quality requirements for designing, conducting, performing, monitoring, auditing, recording, analysing and reporting clinical trials, ensuring that the rights, safety and well-being of subjects are protected and that the data generated are reliable and robust (Art. 2(2)(30) EU Clinical Trials Regulation 536/2014). The international reference is the ICH E6 guideline, whose third revision, ICH E6(R3), was adopted in 2025 and introduces a principles-based, risk-proportionate approach adapted to decentralised and technology-enabled trials.

GCP allocates responsibilities between the sponsor, the investigator and the ethics committee, and sets expectations on informed consent, protocol compliance, safety reporting, quality management, computerised systems, essential documents in the trial master file, monitoring and record retention. GCP inspections by the EMA network, national competent authorities and the FDA verify compliance at sponsors, CROs and sites.

GCP and the GDPR overlap but do not coincide. GCP requires confidentiality of subject records and coding of data, which supports pseudonymisation; GDPR adds a legal basis analysis, data subject rights, DPIAs, transfer mechanisms and breach notification that GCP does not address. Conversely, GCP's data integrity and 25-year retention requirements constrain the GDPR rights to erasure and rectification. iliomad's resource centre offers a visual comparison of ICH GCP and the GDPR.

Does GCP compliance remove the need for a separate data-protection assessment?

No. GCP protects participants and supports reliable trial results, but it does not replace the applicable data-protection framework. Alongside trial-quality controls, assess the lawful processing of personal information, transparency and handling of individual rights. Align the two workstreams so consent materials and operational procedures do not make conflicting promises.