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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.

L

Local site investigator

A local site investigator is the investigator responsible for conducting a multicentre clinical trial at one specific clinical trial site, as distinct from the coordinating (or national coordinating) investigator who, under Art. 71 CTR 536/2014, coordinates the investigators across sites in a Member State. In practice the term is used interchangeably with site principal investigator.

The local site investigator is accountable for everything that happens to trial subjects at their site: screening against eligibility criteria, obtaining informed consent, delivering the protocol-specified treatment and procedures, recording source data and completing the eCRF, reporting adverse events, managing the investigational medicinal product, and supervising sub-investigators, study coordinators and nurses whose tasks are recorded on a delegation log. They host monitoring visits by the sponsor or CRO, audits and regulatory inspections.

From a data protection perspective the local site (the hospital or practice, rather than the individual) is a controller for the identifying patient records and holds the pseudonymisation key. Local investigators are often the persons to whom participants address data subject requests, so they need clear procedures agreed with the sponsor on how to handle access, rectification and withdrawal requests within the constraints of GCP and the research safeguards of Art. 89 GDPR.

Can a local investigator delegate trial tasks without retaining oversight?

No. Delegating tasks does not remove the investigator’s responsibility for appropriate oversight of activities within their remit. Use suitably qualified staff, provide the necessary trial information and document delegation proportionately. At site level, clarify who handles consent, data entry, safety escalation and participant queries, and how the investigator checks those activities.