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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.

H

HHS Office for Civil Rights (OCR)

The HHS Office for Civil Rights (OCR) is the office within the US Department of Health and Human Services responsible for enforcing the HIPAA Privacy and Security Rules. For life sciences organisations, its relevance depends on the organisation’s activities and HIPAA role, not simply whether it handles health-related information.

Key takeaways

  • HHS OCR enforces HIPAA privacy and security protections; OCR is not the agency that authorises medicines or medical devices.
  • HIPAA applies to covered entities and business associates, so a role assessment should precede a claim of universal HIPAA applicability.
  • OCR publishes enforcement information and resolution agreements, which can inform practical reviews of privacy, security and incident-response controls.

How OCR Fits Into Oversight

FunctionOperational significance
Complaint handlingRespond with clear facts and records
Compliance investigationExplain the applicable HIPAA role and safeguards
Resolution and corrective actionAddress identified weaknesses and agreed obligations

HHS describes OCR’s enforcement role and publishes examples of corrective actions. An investigation, a resolution agreement and a finding of liability are not interchangeable labels. Avoid presenting a settlement as a court judgment or treating another organisation’s settlement terms as a universal checklist.

For example, consider a hypothetical research vendor receiving an OCR enquiry after a hospital incident. The first preparation step is to establish what services the vendor provided, which records it held and which contractual and regulatory responsibilities applied.

Why It Matters for Data Protection

The HHS covered-entity guidance explains that business associates have direct obligations under certain HIPAA provisions as well as contractual duties. Operationally, maintain the role analysis, relevant agreements, security evidence and incident chronology together.

We recommend separating HIPAA reporting analysis from FDA safety reporting and other privacy regimes. One event may need several assessments, but notifying one authority should not be assumed to satisfy every obligation.

Frequently Asked Questions

Does OCR approve a clinical trial?

No. Its HIPAA enforcement role is separate from trial authorisation and ethics review.

Is every biotech regulated by OCR under HIPAA?

No. Determine whether the activities create covered-entity or business-associate status.

Are all OCR investigations public?

No. HHS says OCR generally does not disclose current or potential investigations.

Related: HIPAA; protected health information; HIPAA support.

Updated: 27 October 2026