Materials exchanged with British Association of Beauty Therapy and Cosmetology (BABTAC) regarding non-surgical cosmetic procedures regulation: FOI release

Information requested

I have read BABTAC’s public statement concerning the Scottish Government’s non-surgical cosmetic procedures legislation. In that statement, BABTAC says that it had supported and advised the Scottish Government for years, that it played an instrumental role in revisions to the Bill, and that its recommendations were accepted.

I am seeking recorded information about BABTAC’s role, and how the Scottish Government assessed whether BABTAC and Lesley Blair MBE represented the interests of beauty therapists and independent aesthetic practitioners.

Please provide the following recorded information.

1. BABTAC’s role in the policy process

Please provide copies of all correspondence, meeting notes, minutes, agendas, submissions, briefing notes, policy papers and recommendations exchanged between the Scottish Government and BABTAC about non-surgical cosmetic procedures regulation from 1 January 2019 to the date of this request.

Please include records involving Lesley Blair MBE where she was acting for, representing, or associated with BABTAC.

2. Recommendations made by BABTAC

BABTAC has publicly stated that its recommendations were accepted.

Please provide:

• Copies of all recommendations submitted by BABTAC or Lesley Blair MBE.
• Any Scottish Government record showing which BABTAC recommendations were accepted.
• Any Scottish Government record showing which BABTAC recommendations were rejected or amended.
• Any recorded reasons for accepting, rejecting, or amending those recommendations.

3. Representation of beauty therapists and independent practitioners

Please provide all recorded information showing how the Scottish Government assessed whether BABTAC or Lesley Blair MBE represented the interests of:

• Beauty therapists.
• Independent aesthetic practitioners.
• Practitioners from a non-healthcare background.
• Self-employed practitioners.
• Small and micro-businesses in the beauty and aesthetics sector.

4. Impact on practitioners from a beauty background

Please provide all recorded information showing whether the Scottish Government considered the impact of BABTAC’s recommendations on practitioners from a beauty therapy background, including those who were already trained, insured, trading, and providing aesthetic treatments before the Bill was introduced.

5. Meetings involving BABTAC or Lesley Blair MBE

Please provide the minutes, agendas, attendance lists, papers, action logs and declarations of interest for any meetings attended by BABTAC or Lesley Blair MBE concerning non-surgical cosmetic procedures regulation.

This includes meetings with:

• Scottish Government officials.
• Ministers.
• The Interventions Expert Group.
• Healthcare Improvement Scotland.
• Professional associations.
• Any other stakeholder group involved in the policy.

Response

Within this response, I enclose some of the information you requested. The answers to your question are as follows.

Answers to part 1

Documents relating to your first question 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.

Some of the information you have requested is already available from previous FOI requests at Meetings details of the Scottish Cosmetic Interventions Expert Group (SCIEG) from its formation: 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.

Answer to part 2-5

You can find the response submitted to the public consultation, (which closed on 14 February, 2025) by Lesley Blair, on behalf of BABTAC here: Regulation of non-surgical cosmetic procedures - Scottish Government consultations - Citizen Space. You can also find the Scottish Government’s response via that link.

In the answer to part 1 of your question, we have disclosed all correspondence, meeting notes, minutes, agendas, submissions, briefing notes, policy papers and recommendations between BABTAC and SG as requested. The main route by which we sought this input was via the SCIEG meetings. We did not identify further information relevant to your request beyond the documents which we have disclosed.

Regarding, part 4 of your query, you may be interested in the Business and Regulatory Impact Assessment on the Licensing and Further Regulation of Non-Surgical Procedures published in October 2025 on the Scottish Government website, which can be found here. This details an assessment of the anticipated impacts of the proposed regulation and licensing of non-surgical procedures in Scotland. In relation to third party meetings, and meetings we did not attend, as referred to in part 5 of your request, the Scottish Government does not hold information on meetings held by third parties, or on meetings we did not attend.

Insofar as the information released, or the information already reasonably available to you (as highlighted in relation to part 1 of the request), does not contain documents of a description given in your request please  consider this formal notice under section 17 of FOISA that this information is not held.

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 202600516353 - Information Released - Annex 1

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