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The general data protection regulation, the clinical trial regulation and some complex interplay in paediatric
1Centre For Pediatric Clinical Development, PRA Health Sciences, 500 South Oak Way, Green Park, Reading, RG2 6AD, UK. dalrympleharris@prahs.com.
Insights
Ensuring children's rights in clinical trials under the General Data Protection Regulation (GDPR) requires careful protocol drafting. This paper offers solutions for specific GDPR challenges in paediatric clinical trials.
Area of Science:
- Clinical trial regulation
- Paediatric research ethics
- Data privacy law
Background:
- The General Data Protection Regulation (GDPR) impacts clinical trial conduct.
- Existing literature addresses GDPR in adult clinical trials.
- Specific challenges of GDPR in paediatric trials remain underexplored.
Purpose of the Study:
- To examine the impact of GDPR on paediatric clinical trials.
- To identify unique GDPR considerations for minors in clinical research.
- To propose practical approaches for ensuring children's rights under GDPR.
Main Methods:
- Review of GDPR provisions relevant to clinical trials.
- Analysis of age-related consent differences across jurisdictions.
- Examination of protocol complexities in paediatric trials, including pregnancy scenarios.
Main Results:
- Paediatric trials present distinct GDPR challenges compared to adult trials.
- Discrepancies in age of consent for data privacy and trial participation exist.
- Standard clinical trial protocols often fail to address specific GDPR requirements for minors.
Conclusions:
- Conducting paediatric clinical trials in compliance with GDPR is feasible.
- Careful protocol development is essential to navigate GDPR complexities.
- The paper offers solutions for specific GDPR application scenarios in paediatric research.
Abstract:
Although a number of authors have commented upon the impact of the GDPR on clinical trial conduct, few have examined the specific setting of paediatric trials. Whilst the general principles are the same as those for adults, some additional considerations arise. The ages of consent relating to data privacy and clinical trial participation are different in a number of countries, but the distinction is often not recognised in non-drug trials. Accidental pregnancies in clinical trials always raise complexities, but these are amplified when the trial subject is a minor, and the processes described in clinical trial protocols rarely take account of GDPR requirements. This paper describes approaches which can be taken to ensure the rights of children are respected.Conclusion: The conduct of paediatric clinical trials within GDPR requirements is quite possible provided authors think carefully when drafting protocols. What is Known: • GDPR is applicable to clinical trials, including paediatric trials. • A number of challenges at the interface between the GDPR and CTR have been described. What is New: • The application of the GDPR to certain specific situations in paediatric trials does not appear to have been explored. • Three such situations are described and solutions offered.
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