FOI/202600527689 · FOI · not held
Discussions with education providers relating to implementation of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026: FOI release
Information requested
Please provide the following recorded information held from 1 January 2024 to the date of this request.
1. All recorded communications, meeting notes, invitations, agendas, briefings, emails, Teams messages, attachments or other records concerning discussions with: a. Glasgow Caledonian University; b. the University of the West of Scotland; c. City of Glasgow College or any body referred to as Glasgow College; d. any other university, college, awarding organisation or training provider,
where the subject included non-surgical cosmetic procedures, practitioner qualifications, competency, training standards, implementation of the 2026 Act or secondary legislation.
2. For each discussion, please provide recorded information showing: a. who initiated it; b. who attended; c. the date and purpose; d. the qualifications, courses or education routes discussed; e. whether healthcare-professional-only entry was discussed; f. whether pathways for experienced independent practitioners were considered; g. whether recognition of prior learning, existing experience or Level 4 to Level 7 qualifications was discussed; h. whether any provider was invited or encouraged to develop or deliver a future qualification.
3. All recorded communications between the Scottish Government and Glasgow Caledonian University concerning: a. the Postgraduate Diploma in Non-Surgical Medical Aesthetics Practice; b. the earlier MSc NAPP pathway proposal, concept paper or SBAR; c. eligibility being restricted to registered healthcare professionals; d. whether the GCU programme might support, align with or contribute to secondary legislation, implementation or workforce development.
4. Any recorded information showing whether officials discussed or assumed that: a. particular procedures would be restricted to healthcare professionals; b. independent practitioners would require retraining or new qualifications; c. only university-led or healthcare-led qualifications would be recognised; d. existing regulated qualifications might not be accepted; e. transitional arrangements, recognition of prior learning or grandfathering would be required.
5. Any recorded consideration of whether it was appropriate to begin discussions with education providers before completing a workforce analysis of existing practitioners, qualifications and training centres.
Where information is withheld, please identify the exemption relied upon and the category of information withheld. Where no information is held, please issue the appropriate notice under section 17 of FOISA.
Response
Please note that I have numbered your questions to clearly refer to them in my response.
Answers to Questions 1, 2 and 3
Some of the documents relating to Glasgow Caledonian University have been released to you in our response to you on 13 July to your FOI request (reference 202600521873). The remaining documents are available in the response to FOI 202600516504, which is published on the Scottish government website. You can access these documents at Records relating to Glasgow Caledonian University’s Postgraduate Diploma in Non-Surgical Medical Aesthetics Practice: FOI release - gov.scot.
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 website(s) listed, then please contact me again and I will send you a paper copy.
I conducted a search for information in relation to the University of the West of Scotland; City of Glasgow College or any body referred to as Glasgow College, and; any other university, college, awarding organisation or training provider. The results of the search are available at Annexes 1, 1A and 2. While our aim is to provide information whenever possible, in this instance we are unable to provide some 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 sections 30(b)(ii) (free and frank exchange of views) and s.33(1)(b) (commercial interests)] of FOISA applies 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.
Exemption 33(1)(b) applies because disclosure would, or would be likely to, prejudice substantially the commercial interests of the university. The withheld information concerns the development of a new course and contains commercially sensitive information relating to the university's course design. Disclosure would be likely to place the university at a commercial disadvantage by revealing information that competitors could use in the development or marketing of comparable courses. We therefore consider that substantial prejudice to the university's commercial interests would be likely to result from disclosure. We have considered the public interest test and recognise that there is a public interest in openness and transparency, particularly in relation to the activities of publicly funded bodies. However, there is also a strong public interest in protecting the ability of universities to operate effectively in a competitive higher education market. Disclosure of commercially sensitive information relating to a course under development could damage the university's competitive position and its ability to attract students and investment. On balance, we have concluded that the public interest in maintaining the exemption outweighs the public interest in disclosure.
Answer to Question 4
Part 4a of your request asks for recorded information of officials’ discussions that particular procedures would be restricted to healthcare professionals. The Scottish Government’s analysis and response to the consultation on Non-surgical Procedures consultation summarises its proposals in regards to the restriction of some procedures to certain healthcare professionals.
On this basis records of the type referred to in part 4a your request are not held, please consider this formal notice of that fact under Section 17 of FOISA.
In relation to Questions 4b to 4e, specific training and qualification requirements are not included in the Act nor the Order and have not yet been discussed or set. They will be established following consultation, both with people who work in the sector, and with experts, training providers and the UK Government. The information you request is therefore not held. Please consider this formal notice of that fact under Section 17 of FOISA.
Answer to Question 5
Part 5 of your request asks for recorded consideration of whether it is appropriate to begin discussions with education providers before completing a workforce analysis of existing practitioners, qualifications and training centres. As this information is not held, please consider this formal notice of that fact under Section 17 of FOISA.
The Scottish Government has not undertaken a workforce analysis as, apart from healthcare-led services regulated by Healthcare Improvement Scotland, the sector is currently unregulated. However, an estimation was made of the number of businesses likely to be affected by the legislation in the Financial Memorandum and the Business and Regulatory Impact Assessment which were prepared for introduction of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill in October 2025.
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
Where information is withheld, please identify the exemption relied upon and the category of information withheld. Where no information is held, please issue the appropriate notice under section 17 of FOISA. Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. While our aim is to provide information whenever possible, in this instance we are unable to provide some 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 sections 30(b)(ii) (free and frank exchange of views) and s.33(1)(b) (commercial interests)] of FOISA applies to that information.