Documentation regarding stakeholder engagement process and information session pertaining to non-surgical cosmetics procedure bill: FOI release

Information requested

1. Design and Purpose of the Information Session

• All internal documents, briefing notes, emails or meeting records which define or describe the purpose of the session, including whether it was intended to constitute stakeholder engagement.
• Any documents distinguishing between “information provision” and “stakeholder engagement” in relation to this session.

2. Decision-Making on Session Forma

• All correspondence, internal communications, and planning documents relating to the decision:
• not to provide an advance agenda
• not to include a live question and answer function
• to require questions to be submitted after the session
• Any alternative formats considered (including interactive or moderated engagement options), and reasons for their rejection.

3. Stakeholder Engagement Strategy

• Any formal stakeholder engagement strategy, plan, or framework relating to the Bill.
• Any documents identifying which stakeholder groups were to be engaged, including independent aesthetic practitioners.
• Any records assessing the adequacy or effectiveness of engagement with non-medically qualified practitioners.

4. Equality and Fairness Considerations

• Any Equality Impact Assessments, Fairer Scotland Duty assessments, or similar analyses relating to stakeholder engagement for this Bill.
• Any internal discussion or assessment of whether the chosen format of the session could disadvantage or exclude particular practitioner groups.

5. External Influence and Coordination

• Any correspondence between Scottish Government officials and external organisations (including but not limited to professional bodies, advisory groups, or industry organisations) regarding:
• the structure or delivery of the session
• stakeholder engagement approach more broadly

6. Internal Concerns, Risks or Challenges

• Any documents, emails, or meeting notes recording concerns, objections, risks, or limitations relating to:
• the format of the session
• stakeholder engagement more generally
• Any references to reputational risk, criticism, or perceived lack of engagement.

7. Pre-Election Restrictions Justification

• Any internal guidance, correspondence, or legal advice relied upon in determining that preelection
• restrictions required or justified:
• the absence of live engagement
• the restriction of questions to post-event written submissions

If any of the requested information is held but considered exempt, please specify the exemption relied upon and provide any information that can reasonably be disclosed in redacted form.

Please also confirm whether any relevant information is held but not disclosed on the basis of future publication.

Response

Questions 1 and 2

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have all of the information requested. Documents relating to the information event on 25 March following the passing of Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill as per your request are at Annex 1, documents 1 to 5.

Question 3

A non-surgical cosmetics procedure Bill was announced in Programme for Government in May 2025.

We conducted a search relating to your request. While our aim is to provide information whenever possible, in this instance the Scottish Government does not have this information nor records “assessing the adequacy or effectiveness of engagement with non-medically qualified practitioners.” Section 1 of the consultation analysis and response does however, provide information on the Scottish Government’s approach to engagement, including with non-healthcare practitioners prior to the Bill being announced in Programme for Government.

In Document 2 of Annex 1, the Minister for Public Health and Women’s Health provides the Minister for Parliamentary Business and Veterans with details of to whom communication activity is being undertaken at the point of the Bill’s introduction. Those provided with an update included nonhealthcare aesthetic practitioners who attended engagement events in February 2025, or other events or who had responded to the consultation or business survey and agreed to be contacted further regarding non-surgical procedures.

Question 4

In addition to the Scottish Government’s consultation analysis mentioned above, an Equality and Fairer Scotland Duty Impact Assessment for the regulation of non-surgical procedures was conducted and is available on the Scottish Government website. Section 2 of the Business and Regulatory Impact Assessment is specifically in regards to who the Scottish Government has engaged with although references to engagement are made throughout the document.

In regards to whether the chosen format for the March information session could disadvantage or exclude any particular practitioner groups, the session was open to everyone who had previously been in touch with or worked with Scottish Government about this topic and agreed to be contacted again.

Officials arranged the session for after 5pm to account for business working hours to allow as many to join as possible. This decision is highlighted in Annex 1, document 4.

Question 5

There were no external influences or discussion in regards to the structure, delivery or stakeholder engagement for the information session. Therefore, while our aim is to provide information whenever possible, in this instance the Scottish Government does not hold any correspondence between it and external organisations on this matter.

Question 6

Any documents relating to the information session are available in Annex 1.

Question 7

Annex 1, document 3 provides information on pre-election period guidance received in regards to the holding of the information session.

The intention of the session, as set out in Annex 1 Document 4, was to provide factual information on the Bill. Anyone who had questions was invited to share them with Scottish Government via a managed inbox on the night and in the follow up email so it could be responded to accurately.

FOISA Exemption

We are unable to provide some of the information you have requested in the documents in Annex 1 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.

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 202600512523 - Information Released - Annex 1

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