Joint Council for Cosmetic Practitioners (JCCP) concerning aesthetics regulation information: FOI release

Information requested

1. All correspondence, emails, meeting notes, internal briefings and draft documents between the Scottish Government and the JCCP from 1 January 2017 to date.

2. Any documents in which the JCCP is referenced in relation to non-surgical cosmetic procedures, practitioner regulation, licensing, medical reviewers, training standards or enforcement.

3. Any documents assessing the JCCP’s legal status, independence, governance or representativeness.

4. Any documents discussing the JCCP’s relationships with SQA, MHRA, PSA, beauty-sector bodies or medical bodies.

5. Any documents discussing the impact of JCCP-aligned frameworks on independent non-medical practitioners.

6. Any communications between the Scottish Government and public bodies referring to the JCCP as an authority, partner or stakeholder in regulatory design.

Please provide the information electronically.

Response

Question 1 - All correspondence, emails, meeting notes, internal briefings and draft documents between the Scottish Government and the JCCP from 1 January 2017 to date.

Question 2 - Any documents in which the JCCP is referenced in relation to non-surgical cosmetic procedures, practitioner regulation, licensing, medical reviewers, training standards or enforcement.

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.

Due to the broad nature of your request, the searches carried out returned more responses than can be reviewed to provide the information you are seeking. It has not been possible, through searches of our file storage and email systems, to identify documents in scope within the cost limit or separate communications described by part 1 and documents described by part 2 from amongst the documents identified. Documents described in relation to question 2 may have been saved as part of, or following communications with JCCP, and we would consider “communication” with an organisation to include a broad range of different exchanges.

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 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 to a more specific timeframe, as this would allow us to limit the searches that would require to be conducted. You may 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 documents assessing the JCCP’s legal status, independence, governance or representativeness.

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. In the case of JCCP 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 the JCCP’s relationships with SQA, MHRA, PSA, beauty-sector bodies or medical bodies.

A search was conducted for documents relating to JCCP and SQA, MHRA, PSA, HABIA, BABTAC, British Beauty Council, GMC, NMC, GDC, GPhC and HCPC. Documents relating to your request are at Annex 1.

However, 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.

We are also not providing the attachment to the document marked as ‘JCCP Task & Finish Group Paper – 30 October 2025’ because an exemption under section 28(1) (Relations within the United Kingdom) applies. Its disclosure under this Act would, or would be likely to, prejudice substantially relations between the Scottish and UK Governments. This exemption is subject to the 'public interest test', however we have considered that not disclosing the information outweighs the public interest in applying the exemption.

Question 5 - Any documents discussing the impact of JCCP-aligned frameworks on independent non-medical practitioners.

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 documents discussing the impact of JCCP frameworks on independent non-medical practitioners.”

We considered “JCCP-aligned frameworks” 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 considered that this question 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.

The Scottish Government does not hold this information. In the first instance this is because there has not been a reliance on the JCCP frameworks. 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 imply any reliance on ‘JCCP frameworks’.

Given that Scottish Government has not relied on JCCP-aligned frameworks, there is no reference to its impact on independent non-medical practitioners.

Question 6 - Any communications between the Scottish Government and public bodies referring to the JCCP as an authority, partner or stakeholder in regulatory design.

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.

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 202600512258 - Information Released - Annex 1

File type

PDF

File size

1.2 MB