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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.

P

Principal investigator (PI)

A principal investigator (PI) means an investigator who is the responsible leader of a team of investigators who conduct a clinical trial at a clinical trial site (Art. 2(2)(16) EU Clinical Trials Regulation 536/2014). The PI is the person named on the FDA Form 1572 or the EU site documentation, signs the protocol agreement and the clinical trial agreement on behalf of the site (or alongside the institution), and is the primary point of contact for the sponsor, the ethics committee and inspectors.

Under ICH GCP the PI retains ultimate responsibility for the conduct of the trial at the site even when tasks are delegated to sub-investigators, study coordinators, pharmacists or nurses, and must ensure that delegated staff are qualified, trained and listed on the delegation log. Responsibilities include eligibility decisions, informed consent, medical care and safety reporting, IMP accountability, source documentation, timely eCRF completion, and maintenance of the investigator site file for the required retention period.

The PI is a data subject whose curriculum vitae, qualifications, training, financial disclosures and performance metrics are processed by sponsors, CROs and regulators and published in trial registries and the CTIS public portal. The PI's institution is usually the controller for patient source data and the holder of the pseudonymisation key; the PI is responsible in practice for keeping identifying information out of the data sent to the sponsor and for responding, with the sponsor, to participants' data protection requests.