Glasgow Caledonian University Concept Paper on Non-Surgical Cosmetic Practice Education: FOI release

Information requested

You asked for a range of records relating to the document: “MSc NAPP pathway proposal SBAR to consider a regulated educational framework in aesthetic and cosmetic practice”, which was released as part of materials relating to the FoI 202600516504. The information requested is as follows, please note I have renumbered the parts of this request for ease of reference:

1. All records showing who within the Scottish Government received, reviewed, commented on, forwarded, discussed or otherwise handled the GCU concept paper and SBAR between 1 November 2024 and the date of this request.

2. All internal Scottish Government correspondence, meeting notes, Teams messages, briefings, comments, annotations or advice concerning the GCU concept paper and SBAR.

3. All records showing whether the GCU concept paper and SBAR were shared with, discussed with, or referred to any of the following bodies or individuals:

1. Scottish Cosmetic Interventions Expert Group;
2. Healthcare Improvement Scotland;
3. NHS Scotland;
4. SMASG or UK Medical Aesthetics Safety Group;
5. BAMAN;
6. JCCP;
7. Glasgow Caledonian University;
8. Queen Margaret University;
9. University of the West of Scotland;
10. any local authority or environmental health representative;
11. any minister, special adviser, civil servant, policy official, clinical adviser or external stakeholder involved in non-surgical cosmetic procedure policy.

4. All records showing whether Scottish Government officials raised, queried, challenged, accepted or relied upon the wording in the GCU concept paper and SBAR which characterised unregistered aesthetic practitioners as working without background knowledge, understanding or skills in healthcare, including any records showing whether officials considered whether “healthcare” was the correct benchmark for cosmetic aesthetic practice, whether the statement was evidence-based, and whether independent aesthetic practitioners should have been assessed by reference to procedure-specific competence rather than healthcare professional status alone.

5. All records showing whether Scottish Government considered, discussed, accepted, challenged or adopted the proposition that non-surgical cosmetic or aesthetic practice is properly classified as “healthcare”, including any records distinguishing between:

1. aesthetic treatments provided for cosmetic purposes;
2. healthcare services;
3. medical treatment;
4. independent healthcare services regulated by Healthcare Improvement Scotland;
5. procedures involving prescription-only medicines;
6. procedures carried out by healthcare professionals for cosmetic purposes;
7. procedures carried out by independent aesthetic practitioners in non-healthcare settings.

6. All records showing whether Scottish Government officials considered the fairness, evidential basis, equality implications, stakeholder balance or representative accuracy of the GCU concept paper and SBAR before, during or after the December 2024 meeting with GCU.

7. All records showing whether the GCU concept paper and SBAR informed, influenced or were considered in relation to

1. Scottish Government policy on non-surgical cosmetic procedures;
2. future training standards;
3. the position of independent aesthetic practitioners;
4. the role of healthcare professionals in non-surgical cosmetic procedures;
5. Scottish Government discussions with GCU, universities, SCIEG, HIS, SMASG, BAMAN or JCCP.

8. All records showing whether Scottish Government asked GCU to amend, qualify, evidence or reconsider any statements in the concept paper and SBAR concerning independent aesthetic practitioners, unregistered practitioners, non-healthcare professionals, training standards, public safety or NHS burden.

9. Any distribution list, email chain, attachment log, document management record, meeting pack, briefing pack or file note showing where the GCU concept paper and SBAR were stored, circulated or relied upon.

Response

The document referred to in your request was forwarded by Glasgow Caledonian University (GCU) to members of the policy team who were working on the regulation and licensing of non-surgical cosmetic procedures.

Some of the information you have requested is contained within the previous FoI 202600516504 which I understand you have access to. 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 access to the entire response, or require a further copy please let me know and I will forward the response in its entirety. The previous response, searches undertaken and the approach taken to release has been reviewed in detail to ensure that it does access the entirety of your request. In doing so one additional record which is relevant has been identified. This record was not considered in scope of the previous request, but is in scope of part 2 of this request.

In respect of part 1 of your request I can confirm that only members of the policy team responsible for this policy were involved in discussing this document. There is no record that the document was shared further within the Scottish Government, with ministers or otherwise handled until the material was identified in respect of the previous FoI request, at which point it was processed for the purpose of release. Exemptions under section 38(1)(b) apply to the names and details of individual officials. Officials involved work within the Healthcare Quality and Improvement Division of the Directorate for the Chief Operating Officer, NHS Scotland.

In respect of part 2 of your request I have identified one record which is relevant to this request. This record is released as Annex A. Exemptions under sections 38(1)(b) and Section 30(b)(ii) apply to this record, which is an email exchange between officials discussing the document. Section 38(1)(b) applies to the names and details of the officials, these redactions are clearly marked and all the officials are members of the team responsible for this policy area as discussed above. Section 30(b)(ii) applies to some of the content of the email. The content withheld constitutes free and frank exchanges for the purposes of deliberation. Release of this material would substantially inhibit future such free and frank exchanges. The section 30(b)(ii) exemption is subject to the public interest test, I have considered the arguments in favour of release and of maintaining the exemption. I acknowledge that there is some public interest in releasing, however I consider that the public interest in ensuring that officials can discuss and share relevant material without consideration of future release appears outweighs the public interest in release.

In respect of part 3 of your request, I can confirm that there is no record that the document was shared with, discussed with or otherwise referred to in respect of any of the bodies or individuals you have named.

In respect of part 4, 5, 6 and 7 of your request I can confirm that the record referred to under my response to part 2 above is the only record I have identified of any discussion of the document, and the documents released in respect of the previous request constitute the entirety of any engagement with GCU on this subject. I can confirm that none of the material withheld meets the description of discussion given in any of these parts of your request.

In respect of part 8 of your request I note that, as described above, the entirety of the Scottish Government’s engagement with GCU has previously been released, I can confirm that no record is held of the description in this part of your request.

In respect of Part 9 of your request I can confirm that the document was stored in officials’ email inboxes and in the Scottish Government Document Record Management System (including in files relevant to the previous FoI request). There is no record that the document was accessed beyond the team mentioned previously.

Insofar as the material you have described has not been identified, and the material released in the previous request does not meet these descriptions please consider this as a formal notice under Section 17 of FOISA that the material is not held by the Scottish Government.

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 202600521873 - Information Released - Annex A

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