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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.

R

Record of processing activities (RoPA)

The record of processing activities (RoPA) is the written, including electronic, inventory that each controller and, where applicable, its EU representative must maintain under Art. 30(1) GDPR, and that each processor must maintain for the processing carried out on behalf of its controllers under Art. 30(2). It must be made available to the supervisory authority on request and is usually the first document requested in an investigation.

The controller's record must contain, for each processing activity: the name and contact details of the controller, any joint controller, representative and DPO; the purposes; the categories of data subjects and of personal data; the categories of recipients, including those in third countries; any international transfers and their safeguards; the envisaged retention periods; and a general description of the security measures. Processors record their controllers, categories of processing, transfers and security measures. The exemption in Art. 30(5) for organisations with fewer than 250 employees does not apply where processing is not occasional or involves special category data, so virtually every life sciences company must keep one.

A useful RoPA for a sponsor or HealthTech company is organised by purpose (clinical trial conduct, pharmacovigilance, medical information, HR, marketing, platform operation), links each activity to its legal basis, processor contracts and DPIA, and is reviewed at each new study, vendor or system. iliomad maintains RoPAs as part of its outsourced DPO and DPR mandates.