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FOI/202600528362 · FOI · not held

Non-Surgical Procedure qualification requirements: FOI release

Published
2026-08-17
Received
2026-07-16
Responded
2026-08-12
Directorate
Chief Operating Officer, NHS Scotland Directorate
Topic
Health and social care, Public sector
Exemptions
17(1), 38(1), 30

Information requested

Please provide the following recorded information held from 1 January 2018 to the date of this request:

1. All correspondence, meeting records, notes of discussions, briefing documents and submissions exchanged between Scottish Government officials or ministers and VTCT, or any company or body within the VTCT Group, concerning aesthetics, injectable treatments, non-surgical cosmetic procedures, training standards, qualification requirements or assessment criteria.

2. Any recorded information explaining the basis upon which VTCT criteria were referenced in Annex 1 to Scottish Government FOI response 202600523109, including who supplied, checked, verified or approved the information that VTCT criteria existed for the procedures listed.

3. Any recorded information concerning the VTCT Level 7 Diploma in Clinical Aesthetic Injectable Treatments, the JCCP Competency Framework, JCCP approval of VTCT qualifications, or any proposed equivalence between those materials and requirements under the Scottish legislative framework.

4. Any recorded information concerning whether VTCT, or any other awarding organisation, has been approached, consulted, invited or commissioned to develop, adapt, map, approve or deliver qualifications connected with the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026, its implementation or any secondary legislation made under it.

5. Any recorded information concerning proposed restrictions on access to relevant qualifications by reference to statutory healthcare registration, professional title or membership of a particular practitioner category.

6. Any list of awarding organisations considered by the Scottish Government when preparing Annex 1 or later work concerning qualification requirements for non-surgical procedures.

Response

While our aim is to provide information whenever possible, in this instance the Scottish Government does not hold all of the information you have requested.

For clarity, I have addressed each part of your request separately below:

1. All correspondence, meeting records, notes of discussions, briefing documents and submissions exchanged between Scottish Government officials or ministers and VTCT, or any company or body within the VTCT Group, concerning aesthetics, injectable treatments, non-surgical cosmetic procedures, training standards, qualification requirements or assessment criteria.

The Scottish Government does not hold recorded information within the scope of this part of your request. No engagement between Scottish Government officials or Ministers and VTCT, or any company or body within the VTCT Group, was identified by the searches undertaken. Accordingly, this is a formal notice under section 17(1) of FOISA.

2. Any recorded information explaining the basis upon which VTCT criteria were referenced in Annex 1 to Scottish Government FOI response 202600523109, including who supplied, checked, verified or approved the information that VTCT criteria existed for the procedures listed.

I enclose a copy of some of the information you have requested. While our aim is to provide information whenever possible, in this instance we are unable to provide all of the information you have requested because an exemption under Section 38(1)(b) of FOISA applies. This relates to personal information, and as such redactions have been applied clearly identifying the reason for the redaction. Wherever possible contextual information (such as the domain of email addresses) has been retained to assist understanding of the exchanges.

We are also unable to provide some of the information you have requested because exemptions under section 30(b)(ii) (free and frank exchange of views) of FOISA apply to that information. Exemption 30(b) (ii) applies because disclosure would, or would be likely to, inhibit substantially the free and frank exchange of views for the purposes of deliberation. The withheld information records candid discussions and opinions that were exchanged to inform policy development and decision-making.

Disclosure would be likely to reduce the willingness of participants to engage openly and frankly in future discussions. This exemption is subject to the public interest test. We recognise that there is a public interest in openness, transparency and informing public debate about the development of policy.

However, there is also a strong public interest in ensuring that officials and stakeholders can exchange views freely and frankly while options are being considered. In this case, we have concluded that the public interest in maintaining the exemption outweighs the public interest in disclosure.

3. Any recorded information concerning the VTCT Level 7 Diploma in Clinical Aesthetic Injectable Treatments, the JCCP Competency Framework, JCCP approval of VTCT qualifications, or any proposed equivalence between those materials and requirements under the Scottish legislative framework.

The Scottish Government does not hold recorded information within the scope of this part of your request. Accordingly, this is a formal notice under section 17(1) of FOISA.

4. Any recorded information concerning whether VTCT, or any other awarding organisation, has been approached, consulted, invited or commissioned to develop, adapt, map, approve or deliver qualifications connected with the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026, its implementation or any secondary legislation made under it.

The Scottish Government does not hold recorded information within the scope of this part of your request. Accordingly, this is a formal notice under section 17(1) of FOISA.

5. Any recorded information concerning proposed restrictions on access to relevant qualifications by reference to statutory healthcare registration, professional title or membership of a particular practitioner category.

The Scottish Government does not hold recorded information within the scope of this part of your request. Accordingly, this is a formal notice under section 17(1) of FOISA.

6. Any list of awarding organisations considered by the Scottish Government when preparing Annex 1 or later work concerning qualification requirements for non-surgical procedures.

The Scottish Government does not hold recorded information within the scope of this part of your request. Accordingly, this is a formal notice under section 17(1) of FOISA.

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

Accordingly, this is a formal notice under section 17(1) of FOISA. While our aim is to provide information whenever possible, in this instance we are unable to provide all of the information you have requested because an exemption under Section 38(1)(b) of FOISA applies. We are also unable to provide some of the information you have requested because exemptions under section 30(b)(ii) (free and frank exchange of views) of FOISA apply to that information. Exemption 30(b) (ii) applies because disclosure would, or would be likely to, inhibit substantially the free and frank exchange of views for the purposes of deliberation. This exemption is subject to the public interest test.

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