Joint Council for Cosmetic Practitioners (JCCP) correspondence in relation to non-surgical cosmetic procedures regulation: FOI release

Information requested

This request concerns Lesley Blair MBE, BABTAC, the Joint Council for Cosmeic Practitioners, known as the JCCP, and Professor David Sines, in relation to Scottish Government work on non-surgical cosmetic procedures regulation.

Please provide the following recorded information.

1. Scottish Government awareness of Lesley Blair MBE’s JCCP connection

Please provide all recorded information showing whether the Scottish Government, its officials, Ministers, working groups, expert groups, or advisers were aware of any affiliation, connection, support, advisory relationship, working relationship, or policy alignment between Lesley Blair MBE and the JCCP.

This should include:

• Emails.
• Meeting notes.
• Declarations of interest.
• Conflict of interest forms.
• Registers of interest.
• Briefing notes.
• Internal discussions.

Any assessment of whether this affected her ability to represent beauty therapists or independent aesthetic practitioners.

2. JCCP, BABTAC and Lesley Blair MBE

Please provide all recorded information from 1 January 2019 to the date of this request referring to the JCCP in connection with:

• BABTAC.
• Lesley Blair MBE.
• The Scottish Government’s Interventions Expert Group.
• Scottish non-surgical cosmetic procedures policy.
• Practitioner eligibility.
• Supervision of non-healthcare practitioners.
• Licensing or restriction of non-healthcare practitioners.
• Education, training, competency or registration standards.

3. Conflict of interest management

Please provide all recorded information showing how any actual, potential, or perceived conflict of interest was managed in relation to Lesley Blair MBE’s involvement in Scottish Government work on non-surgical cosmetic procedures.

Please include any records considering:

• Her BABTAC role.
• Any JCCP affiliation, connection, or alignment.
• Her ability to represent the wider beauty sector.
• Her ability to represent practitioners who are not doctors, dentists, nurses, pharmacists, or other healthcare professionals.
• Any difference between BABTAC’s policy position and the interests of independent aesthetic practitioners.

4. Professor David Sines and Lesley Blair MBE

Please provide all recorded information held by the Scottish Government referring to both Professor David Sines and Lesley Blair MBE in connection with:

• Non-surgical cosmetic procedures regulation.
• The Interventions Expert Group.
• BABTAC.
• The JCCP.
• Practitioner eligibility or restriction.
• Education, training, standards, registration, or competency frameworks.

5. Professional recognition, awards, honours or endorsements

Please provide any recorded information held by the Scottish Government referring to any professional recognition, award, honour, nomination, recommendation, endorsement, congratulations, or support relating to Lesley Blair MBE, where such information is held in connection with Scottish Government policy work, advisory work, expert group work, or stakeholder engagement concerning non-surgical cosmetic procedures.

For clarity, I am not asking the Scottish Government to speculate or create new information. I am asking only for recorded information it holds.

6. Assessment of whether JCCP represented independent practitioners

Please provide all recorded information showing whether the Scottish Government considered whether the JCCP represented, or did not represent, independent aesthetic practitioners from a beauty therapy background.

Please include records discussing whether the JCCP’s policy position aligned with, conflicted with, or excluded the interests of non-healthcare aesthetic practitioners.

Response

I enclose a copy of some of the information you requested. While our aim is to provide information whenever possible, in this instance the Scottish Government does not have some of the information you have requested. The reasons why we do not have all of the information are explained in this letter.

Part 1

A search was conducted for the documents relating to your question. All documents found relating to this question 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.

No information was found assessing whether Lesley Blair's JCCP connection affected her ability to represent beauty therapists or independent aesthetic practitioners.

Please consider this formal notice under section 17 of FOISA that this information is not held.

Part 2

Some of the information you requested in Part 2 has already been released. Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you.

Information that you ask for in relation to SCIEG has already been released, and can be found at:

https://www.gov.scot/publications/foi-202600511018/

https://www.gov.scot/groups/scottish-cosmetic-interventions-expert-group/

https://www.gov.scot/publications/foi-202600510950/

https://www.gov.scot/publications/foi-202500447461/

https://www.gov.scot/publications/foi-202500448384/

Further information in relation to JCCP has been previously released, and is at:

https://www.gov.scot/publications/foi-202600512258/

https://www.gov.scot/publications/foi-202600508622/

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.

The documents released at Annex 1 in reference to Part 1 constitute some of the information also retrieved through searches carried out in identifying information requested at Part 2. All further information found relating to Part 2 has been provided at Annex 2.

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.

Part 3

Further material relating to the declaration of interests made by Lesley Blair has been released in Annex 3 to this request. However, the Scottish Government does not have the information you have asked for relating to the management of these interests, or relating to any conflict of interests. Members of SCIEG were invited to join the group because of their relevant expertise. It is expected that members would have interests to declare, and other roles related to their expertise. Such interests, or the existing of other relevant roles do not necessarily constitute a conflict of interest.

As such, I hereby provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.

Part 4

Documentation related to Lesley Blair and David Sines, meeting the description of Part 4 of your request, has been released under parts 1 and 2 of this request, and no additional material has been found. Insofar as the material released or referred to related to Part 1 or 2 does not meet the descriptions you have given under Part 4 of the request please consider this formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.

Part 5

The Scottish Government does not have the information you have asked for because the Scottish Government was not involved with any professional recognition, award, honour, nomination, recommendation, endorsement, congratulations, or support relating to Lesley Blair MBE.

As such, I hereby provide you with formal notice under section 17(1) of FOISA that the Scottish Government does not have the information you have requested.

Part 6

The Scottish Government does not have the information you have asked for. 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) Act and The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026. JCCP were consulted due to their role and expertise in operating a not for profit practitioner register accredited by the Professional Standards Authority as part of its Accredited Register Programme.

As such, I hereby provide you with formal notice under section 17(1) of FOISA that 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 202600516357 - Information Released - Annex 1 - 3

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