FOI/202600529271 · FOI · already published
Regulation of non-surgical cosmetic procedures for independent aesthetic practitioners: FOI release
Information requested
Please provide recorded information concerning the involvement of practising independent aesthetic practitioners in the development of the Scottish Government’s proposals for regulating non-surgical cosmetic procedures - ie not an HCP or anyone associated in any way with a nurse, doctor or medical association, register, council or board.
This request distinguishes between: people who submitted responses to the public consultation; people or organisations given direct involvement in developing the consultation, policy or regulatory proposals; and practising independent aesthetic practitioners who had no recorded role or formal relationship with the Joint Council for Cosmetic Practitioners, known as the JCCP. For the period 1 January 2020 to the date of this request, please provide the following recorded information.
1. Direct practitioner involvement
Please provide the number of practising independent aesthetic practitioners who were directly involved in developing, discussing or advising upon:
a. the consultation questions;
b. the proposed procedure groupings;
c. the proposed restrictions upon who may perform procedures;
d. the proposed premises requirements;
e. the proposed Healthcare Improvement Scotland requirements;
f. any requirement for an authorised prescriber or healthcare professional to be present; and
g. the Scottish Government’s response to the consultation.
2. Information about participating practitioners
For each person counted under point 1, please state, where recorded:
a. the advisory group, meeting, workshop, subgroup or other process in which the person participated;
b. whether the person was invited, appointed, nominated or selected;
c. whether the person participated personally as a practising independent aesthetic practitioner or as a representative of an organisation;
d. the procedures that the person was recorded as personally performing;
e. the dates or period of the person’s involvement; and
f. the person’s length of experience as a practising aesthetic practitioner, where this was recorded or supplied to the Scottish Government.
Personal contact details are not requested. Names may be withheld where a statutory exemption applies, but please provide the remaining recorded information and aggregate figures.
3. Independence from the JCCP
Please provide the number of people counted under point 1 who had no recorded role, membership, trusteeship, committee position, advisory position, partnership or other formal relationship such as a memorandum of understanding with the JCCP.
Please provide the recorded information used by the Scottish Government to establish whether any person or organisation presented as representing independent aesthetic practitioners was independent of the JCCP.
4. Organisations treated as representatives
Please provide a list of every organisation treated by the Scottish Government as representing independent aesthetic practitioners during the policy-development process, together with:
a. the basis upon which the organisation was selected or recognised as representative;
b. any membership figures supplied to the Scottish Government;
c. whether those membership figures distinguished practising independent aesthetic practitioners from healthcare professionals, educators, suppliers, clinics or other members;
d. whether the organisation held a position within, or had another recorded formal relationship with, the JCCP such as a trustee; and
e. whether the Scottish Government recorded any conflict of interest or overlapping organisational role.
5. Membership of advisory groups and meetings
Please provide the number of practising independent aesthetic practitioners who participated in each of the following:
a. the Scottish Cosmetic Interventions Expert Group;
b. the Cosmetics Informed and Empowered Public Subgroup;
c. the Business Review Group;
d. any working group concerned with procedure classification, premises requirements, qualifications or practitioner eligibility;
e. targeted stakeholder meetings or workshops held outside those groups; and
f. any other group that contributed directly to the proposed regulatory model.
Please count unique individuals separately from organisational representatives and avoid counting the same person more than once within each category.
6. Selection and conflicts records
Please provide copies of any:
a. invitations;
b. selection criteria;
c. nomination records;
d. membership records;
e. declarations of interest; and
f. conflict-of-interest records concerning the involvement of independent aesthetic practitioners or organisations said to represent them.
7. Assessment of representative balance
Please provide any recorded assessment of whether participation by practising independent aesthetic practitioners was sufficient, representative or balanced when compared with participation by:
a. statutory healthcare professionals;
b. professional healthcare bodies;
c. regulatory bodies;
d. organisations connected with the JCCP; and
e. beauty-sector membership organisations.
8. Practitioners who were not selected
Please provide any records identifying independent aesthetic practitioners or independent practitioner organisations that were considered for participation but were not invited, appointed or selected, including any recorded reasons for those decisions.
9. Public consultation respondents
Separately, please provide the number of public consultation respondents whom the Scottish Government, or its consultation-analysis contractor, recorded as:
a. practising independent aesthetic practitioners;
b. independent aesthetics business owners;
c. beauty therapists performing non-surgical aesthetic procedures; or
d. respondents falling within another equivalent category.
Please provide these figures only where respondent status was recorded. No attempt to identify anonymous respondents is requested.
10. BABTAC and the British Beauty Council
For the figures supplied in response to points 1, 3, 4 and 5, please exclude BABTAC and the British Beauty Council from any total described as independent practitioner representation. Please show the participation of BABTAC and the British Beauty Council separately, including:
a. the groups, meetings or workshops in which each participated;
b. the capacity in which each participated; and
c. any recorded JCCP roles or formal relationships known to the Scottish Government at the time.
11. Other JCCP-connected participants
Please identify separately every other person or organisation counted as representing independent practitioners that had a recorded JCCP role or formal relationship.
12. Remaining independent representation
After excluding BABTAC, the British Beauty Council and every other participant or organisation with a recorded JCCP role or formal relationship, please state the remaining number of practising independent aesthetic practitioners involved in developing or advising upon the proposals.
Where the Scottish Government does not hold enough recorded information to calculate this figure, please state that clearly and provide any relevant information that is held. Where no recorded information is held for any other part of this request, please state this separately. Where relevant information is already published, please provide the precise document or webpage link rather than a general website address.
Response
1. All responses to the Scottish Government’s 2024/2025 consultation were considered and the Scottish Government’s analysis of, and response to, the consultation provides a breakdown summary of the 2,207 who responded. The analysis and response also provides details of further stakeholder engagement for the Bill and this included two engagement events specifically for non-healthcare practitioners at which we heard the views and concerns of 71 participants. A copy of the invitation for these events is provided as part of our response to Question 6.
Following the Bill’s introduction, practitioners, businesses, clients in the sector and stakeholders were also provided an opportunity to feed into the Bill process through calls for views from the Scottish Parliament’s Health, Social Care and Sport Committee and the Finance and Public Administration Committee. The Committee heard from non-healthcare practitioners and healthcare professionals on 2 and 9 December 2024 respectively. Details of the Stage 1 Committee meeting and report are available on the Scottish Parliament website at Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information.
2. All responses to the Scottish Government’s 2024/2025 consultation were considered and the Scottish Government’s analysis of, and response to, the consultation provides a breakdown summary of the 2,207 who responded. The analysis and response also provides details of further stakeholder engagement for the Bill and this included two engagement events specifically for non-healthcare practitioners at which we heard the views and concerns of 71 participants. A copy of the invitation for these events is provided as part of our response to Question 6.
Following the Bill’s introduction, practitioners, businesses, clients in the sector and stakeholders were also provided an opportunity to feed into the Bill process through calls for views from the Scottish Parliament’s Health, Social Care and Sport Committee and the Finance and Public Administration Committee. The Committee heard from non-healthcare practitioners and healthcare professionals on 2 and 9 December 2024 respectively. Details of the Stage 1 Committee meeting and report are available on the Scottish Parliament website at Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information.
3. The Scottish Government does not have the information you have asked for because we did not identify any recorded information held relating to your request.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
4. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding organisations treated by the Scottish Government as representing independent aesthetic practitioners during the policy-development process.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
5. Some of the information you have requested is available from the Scottish Government website at:
https://www.gov.scot/groups/scottish-cosmetic-interventions-expert-group/
https://www.gov.scot/groups/regulatory-review-group/
Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.
Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information.
5. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding the number of practising independent aesthetic practitioners who participated in each of the groups you have listed.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
6. I enclose a copy of some of the information you requested, accessible as Document 1 in Annex A to this request. An exemption under section s.38(1) of FOISA applies to some of this information because it is personal data of a third party, and disclosing it would contravene the data protection principles in data protection legislation. 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.
Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information.
7. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding whether participation by practising independent aesthetic practitioners was sufficient, representative or balanced when compared with participation by the groups you have listed.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
8. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding independent aesthetic practitioners or independent practitioner organisations that were considered for participation but were not invited, appointed or selected.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
9. Information regarding the breakdown of responses to Scottish Government consultations on the regulation of non-surgical cosmetic procedures is available at:
Analysis of Consultation on the regulation of non-surgical cosmetic procedures, Final Report, July 2022 - Pages 3-4
Regulation and Licensing of non-surgical cosmetic procedures: Consultation analysis and response, June 2025 - Pages 5-6
The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding the specific breakdown of consultation respondents that you have specified.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
10. a) I enclose a copy of some of the information you requested, accessible as Document 2 in Annex A to this request. Some of the information you have requested is available from the Scottish Government website at: FOI 202600517032 - Information released - Annex 1 & Annex 2 - Page 98 - 101 and Scottish Cosmetic Interventions Expert Group.
Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.
Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information.
b) I enclose a copy of some of the information you requested, accessible as Document 2 in Annex A to this request. The information you have requested is available from the Scottish Government website at:FOI 202600517032 - Information released - Annex 1 & Annex 2 - Page 98 - 101 and Scottish Cosmetic Interventions Expert Group.
Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.
c) The information you have requested is available from the Scottish Government website at Joint Council for Cosmetic Practitioners (JCCP) correspondence in relation to non-surgical cosmetic procedures regulation: FOI release - gov.scot - Annex 3.
Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.
11. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding other persons or organisations counted as representing independent practitioners that had a recorded JCCP role or formal relationship.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
12. The Scottish Government does not have the information you have asked for because we do not hold recorded information regarding the number of practising independent aesthetic practitioners involved in developing or advising upon the proposals.
This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.
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
Names may be withheld where a statutory exemption applies, but please provide the remaining recorded information and aggregate figures. Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information. Insofar as the material released does not meet the descriptions given in this part of the request please consider this as formal notification under section 17(1) of FOISA that the Scottish Government does not hold this information. This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested. This is a formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.