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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

Human subjects protection review board

A human subjects protection review board is a committee that reviews, approves and monitors research involving human participants to ensure that their rights and welfare are protected. In the United States the statutory term is Institutional Review Board (IRB), governed by the Common Rule (45 CFR Part 46) and FDA regulations (21 CFR Parts 50 and 56); in Europe the equivalent bodies are ethics committees under the Clinical Trials Regulation and national law. Other jurisdictions use terms such as research ethics board (Canada) or human research ethics committee (Australia).

Whatever the name, the board assesses whether risks to participants are minimised and reasonable in relation to anticipated benefits, whether selection of participants is equitable, whether informed consent will be sought and documented appropriately, whether vulnerable populations such as incapacitated subjects and minors receive additional protections, and whether adequate provisions exist to protect privacy and maintain confidentiality of data.

For sponsors running multinational trials, the practical challenge is reconciling different boards' expectations on consent language, international data transfers, future use of samples and re-contact. A US central IRB will apply HIPAA authorisation requirements, while a French CPP will look for GDPR Art. 13 information and MR-001 compliance. Preparing a global consent template with country-specific data protection annexes, and aligning it with the DPIA, avoids inconsistent submissions and protocol deviations.

Does US IRB approval automatically authorise every use of protected health information?

No. Research ethics review and HIPAA requirements are distinct. Where the HIPAA Privacy Rule applies, the covered entity needs an appropriate route for using or disclosing protected health information, such as authorisation or a valid waiver. Do not assume that a general IRB approval letter addresses every planned data disclosure.