Joint Council for Cosmetic Practitioners (JCCP) documentation: FOI release

Information requested

1. All communications between the Scottish Government and the JCCP since 2017.

2. Any documents referencing JCCP in relation to aesthetic regulation or licensing proposals.

3. Any assessments of JCCP’s governance status.

4. Any documents discussing JCCP’s relationship with beauty sector bodies (HABIA, BABTAC, British Beauty Council).

5. Any internal discussions regarding reliance on JCCP frameworks.

Response

Question 1 - All communications between the Scottish Government and the JCCP since 2017.

Question 2 - Any documents referencing JCCP in relation to aesthetic regulation or licensing proposals.

While our aim is to provide information whenever possible, in regards to requests 1 and 2, the costs of locating, retrieving and providing the information requested would exceed the upper cost limit of £600.

We have found over 1500 documents and emails in our file storage system and emails which we would need to sift through to identify all those relating to questions one and two and to exclude any duplicates. It has not been possible, purely through searches of these systems, to separate communications described by part 1 and documents described by part 2 from amongst the 1500 documents identified. This is because documents described in relation to question 2 may have been saved as part of, or following communications with JCCP, and because we would generally consider “communication” with an organisation to include a broad range of different exchanges and so matter in scope for question 1 may have been saved as part of or alongside documents described in Question 2.

Under section 12 of FOISA public authorities are not required to comply with a request for information if the authority estimates that the cost of complying would exceed the upper cost limit, which is currently set at £600 by Regulations made under section 12.

You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600. For example, you could specify the subject matter(s) of the correspondence or documents you are interested in or restrict your request to a specific business area of the Scottish Government, as this would allow us to limit the searches that would require to be conducted. You will see below that we were able to identify and provide documents discussing JCCP’s relationships with beauty sector bodies, within the cost limit. You may also find it helpful to look at the Scottish Information Commissioner's 'Tips for requesting information under FOI and the EIRs' on  this website at: http://www.itspublicknowledge.info/YourRights/Tipsforrequesters.aspx.

Question 3 - Any assessments of JCCP’s governance status.

A search was conducted for documents relating to your request. While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested.

JCCP is one of many stakeholder organisations and individuals that Scottish Government has engaged with in developing the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill and The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026. Scottish Government is not responsible for the governance status of JCCP or other organisations. In JCCP’s case that would be a matter for its Board and the Professional Standards Authority which accredits JCCP’s register of non-surgical procedures practitioners.

Question 4 - Any documents discussing JCCP’s relationship with beauty sector bodies (HABIA, BABTAC, British Beauty Council).

A search was conducted for documents relating to JCCP and HABIA, BABTAC and British Beauty Council. Documents relating to your request are at Annex 1.

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 5 - Any internal discussions regarding reliance on JCCP frameworks.

While our aim is to provide information whenever possible, in this instance, the Scottish Government does not have the information you have requested. You asked for “Any internal discussions regarding reliance on JCCP frameworks.” It was necessary for the Scottish Government to make certain assumptions in responding to this part of the request, and these are set out below. The reasons why we don’t have the information are also explained.

Question 5: Interpretation

By “JCCP frameworks” we considered that this was a reference to the documentation held by or produced by the Joint Council for Cosmetic Practitioners in relation to expected standards of training or qualification for their members and which may inform the JCCP position on training providers, and any accreditation they may have. Such a framework is published on the JCCP website: JCCP Competency Framework final V8 September 2018.pdf. We understand that there may also be previous versions of this framework and or drafts which may also relate to the scope if this question.

By “reliance” we considered that this would be a reference to any decision to include frameworks as part of an evidence base for any decision made by the Scottish Government.

We considered that material in scope would be any documents, including email exchanges, advice to ministers, meeting notes etc, that discussed any decision to include reliance on JCCP frameworks in establishing the Scottish Government’s position, or that evaluated such documents in preparation for relying on them in this way.

If any of these assumption above are incorrect we may not have looked for the information you are looking for. If this is the case we would apologise and would welcome any further request which may make this clearer and set out in more detail what information you are looking for.

Question 5: Why we don’t hold information / how we established this information was not held

As indicated above/ in the letter the Scottish Government does not hold this information. In the first instance this is because we do not consider that there has been any reliance on the JCCP frameworks, as defined above. The evidence base, policy rationale and outline of policy decisions are to be found in the following documentation:

• Consultation documents (published on the Scottish Government website)
  • Consultation on the Regulation of Non-Surgical Cosmetic Procedures in Scotland
  • Analysis of Consultation on the regulation of non-surgical cosmetic procedures: Final Report
  • Consultation background paper: Regulation and Licensing of Non-surgical cosmetic procedures
  • Non-Surgical Cosmetic Procedures Consultation Analysis and Scottish Government Response
• Impact Assessments (published on the Scottish Government website)
  • Non-Surgical Procedures - Business and Regulatory Impact Assessment
  • Child Rights and Wellbeing Impact Assessment Template - Regulation of non-surgical procedures: child rights and wellbeing impact assessment - gov.scot
  • Regulation of non-surgical procedures: equality and Fairer Scotland Duty impact assessment - gov.scot
  • Regulation of non-surgical procedures: island communities impact assessment consideration - gov.scot
• Accompanying documents for the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill and The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026. (Accompanying documents for the Bill are published on the Scottish Parliament website (Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill| Scottish Parliament Website). The only accompanying document in relation to the Order is the Policy Note available at The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026 - Policy Note)

We searched these documents for references to the JCCP in order to identify any reliance on frameworks, or any references to the JCCP that may indicate that such reliance exists. There are a number of references to the JCCP, mainly in the context of lists of organisations engaged with by the Scottish Government, and, in the Business and Regulatory Impact Assessment, as part of a wider assessment of the role of voluntary registers in self-regulation. None of these references appear to imply any reliance on the JCCP frameworks.

Further to this we also note that none of the proposals currently engage with particular levels of training or qualification, were the JCCP framework to be relied on, or were the Scottish Government to consider relying on this framework it would most likely be in the context of such standards.

On this basis it is clear that the Scottish Government has not put any reliance on the JCCP frameworks, and as such there is no internal discussion of such reliance.

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.

FOI 202600508622 - Information released - Annex 1

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