FOI/202600517032 · FOI · not held
Correspondence between the Scottish Government and British Association of Beauty Therapy & Cosmetology (BABTAC) concerning non-surgical cosmetic procedures: FOI release
Information requested
Please provide the following recorded information for the period 1 January 2018 to 31 March 2026:
1. All correspondence between the Scottish Government and BABTAC concerning non-surgical cosmetic procedures, aesthetics regulation, licensing, practitioner qualifications, beauty therapists, independent practitioners, injectables, dermal fillers, or JCCP.
2. All correspondence between the Scottish Government and HABIA or Skills Active concerning nonsurgical cosmetic procedures, aesthetics regulation, licensing, practitioner qualifications, beauty therapists, independent practitioners, injectables, dermal fillers, or JCCP.
3. All correspondence between the Scottish Government and the British Beauty Council concerning non-surgical cosmetic procedures, aesthetics regulation, licensing, practitioner qualifications, beauty therapists, independent practitioners, injectables, dermal fillers, or JCCP.
4. Any records discussing whether BABTAC, HABIA / Skills Active or the British Beauty Council were treated by Scottish Government as representing the beauty sector, independent practitioners, nonhealthcare practitioners, or non-medical practitioners.
5. Any records discussing whether BABTAC, HABIA / Skills Active or the British Beauty Council’s position was aligned with, influenced by, or shared with the JCCP.
6. Any records discussing the exclusion of injectables or dermal fillers from the scope of practice of beauty therapists, non-healthcare practitioners, non-medical practitioners, or independent practitioners.
Electronic copies are sufficient and PDF format is preferred where applicable.
If this request overlaps in part with any previous correspondence, please treat it as a fresh request for any recorded information not already disclosed.
If you consider any part of this request likely to exceed the appropriate cost limit, please treat this as a request for advice and assistance and confirm how the request may be refined so that the relevant information can still be provided.
Response
Within this response, I enclose some of the information you requested. The answers to your question are as follows.
Answers to Questions 1 and 3.
Documents relating to question 1 and 3 are at Annex X & Y respectively.
Your previous FoI request (FOI/202600508622), was very similar to this one, as such, that release contained information that is relevant to this request. Some of the documents provided in this annex may duplicate the documents that have been released to you previously.
We are unable to provide some of the information you have requested in these documents because an exemption (section 38(1)(b) (personal information)) of FOISA applies. This is because some of this information is personal data of third parties, e.g. names/contact details of individuals, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption. Exemptions under section 38(1) (b) have been simply marked as ‘[Redacted - S.38(1)(b)]' throughout the Annex.
Question 2
In undertaking a search of our systems in regards to Question 2, we were unable to find any correspondence between the Scottish Government and Habia or Skills Active relating to your request. The Scottish Government therefore does not have the information you have asked for. As such, I hereby provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
Question 4
No records were found discussing whether BABTAC, HABIA / Skills Active or the British Beauty Council were treated by Scottish Government as representing the beauty sector, independent practitioners, non-healthcare practitioners, or non-medical practitioners. Please consider this formal notice under section 17 of FOISA that this information is not held.
Question 5
The Scottish Government has engaged with many stakeholders in developing the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act and The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026. Due to their common interests in, or focus on, non-surgical procedures, we appreciate that organisations may engage with each other or the subject however, the Scottish Government has not discussed the relationship between stakeholders such as BABTAC, HABIA, Skills Active nor British Beauty Council with JCCP. As such, I hereby provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
Any information we do hold about the relationship between BABTAC, HABIA, British Beauty Council and JCCP were provided to you in the response to your earlier FOI request of 26 February 2026 (FOI/202600508622).
Question 6
The term ‘scope of practice’ is generally used in relation to regulated professionals. I am not aware of how the concept may be applied to non-healthcare and non-medical aesthetic practitioners who are not regulated, nor am I aware of any evidence that ‘scope of practice’ has been discussed in this context. The discussion around who can practise using injectables and dermal fillers has revolved around the safe administration of these procedures and the management of complications, including the prescribing of prescription-only medicines in the management of any complications. I therefore provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested. However, as previously signposted to you, the consultation analysis: Regulation and licensing of non-surgical cosmetic procedures: consultation analysis and response -gov.scot, sets out both the findings from the consultation and sets out thinking regarding the policy pursued by Scottish Government.
About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.
Detected exemption language
We are unable to provide some of the information you have requested in these documents because an exemption (section 38(1)(b) (personal information)) of FOISA applies. names/contact details of individuals, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the 'public interest test', so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption. Exemptions under section 38(1) (b) have been simply marked as ‘[Redacted - S.38(1)(b)]' throughout the Annex. As such, I hereby provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.