Documentation regarding non-surgical aesthetics education restricted to registered healthcare professionals: FOI release

Information requested

You asked for a range of records in the context of statements made by Glasgow Caledonian University. Your specific request is for information was for recorded information as follows:

1. Any recorded information held by Scottish Government identifying any section, provision, schedule, guidance, policy document, ministerial statement, legal advice, internal analysis or briefing which states or suggests that non-surgical aesthetics education or training courses should be restricted to registered healthcare professionals only.

2. Any recorded information held by Scottish Government identifying whether the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act requires, supports or justifies restricting training, education or competence pathways in non-surgical aesthetics to registered healthcare professionals only.

3. Any recorded information held by Scottish Government showing whether independent aesthetic practitioners are excluded by the Act from relevant education, training or future competence pathways.

4. Any recorded information showing whether Scottish Government advised, instructed, encouraged, endorsed or suggested to GCU that its Postgraduate Diploma in Non-Surgical Medical Aesthetics Practice should be restricted to registered healthcare professionals only.

5. Any correspondence, meeting notes, internal emails, Teams messages, briefings, comments or records between Scottish Government and GCU discussing course eligibility, registered healthcare professional restriction, independent aesthetic practitioners, non-healthcare practitioners, or the legal basis for the course entry criteria.

6. Any recorded information showing whether Scottish Government considered GCU’s public or FOI wording about the course to be accurate, including any wording suggesting that the course was developed in conjunction with Scottish Government or that its eligibility criteria were set in line with Government legislation.

7. Any recorded information showing Scottish Government concern, comment, correction or request for amendment in relation to GCU’s course messaging, including any concern that GCU’s wording could imply Scottish Government endorsement, joint development, or a legal exclusion of independent aesthetic practitioners.

8. Any recorded information created after 10 June 2026 discussing GCU’s FOI/092/2026 response, including the statement that the programme eligibility criteria were set “in line with relevant Government legislation”.

Response

It may be helpful to clarify that Glasgow Caledonian University (“GCU”) operates independently of the Scottish Government, and it remains available for GCU to design courses, set entrance criteria for, and market those courses as they see fit.

I can also confirm that the Scottish Government at the time of your request had not had sight of any FOI response published by GCU, as such this is formal notice under section 17(1) of FOISA that any parts of your request (including part 8 in its entirely) relating explicitly to the

FOI response FOI/092/2026 are not held.

Response to your request – Parts 1, 2 and 3.

Parts 1, 2, and 3 of your request all relate to the Scottish Government position, or understanding of legislation (guidance etc), relating to whether training opportunities are or should be restricted to registered healthcare professionals only.
I can confirm firstly that the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026 does not restrict those who may undertake non-surgical procedures. I can also confirm that the Act does not set any particular training or educational standard, or make any provision related to the provision of education or training courses.

On this basis records of the type referred to in parts 1, 2 and 3 of your request are not held, please consider this formal notice of that fact under Section 17 of FOISA.

Response to your request – Parts 4, and 5

Parts 4 and 5 of your request refer to records relating to engagement between the Scottish Government and GCU in relation to its course. I enclose a copy of the records found which matched the description of part 5 of your request. As you will see from these documents the Scottish Government has had only limited engagement with Glasgow Caledonian University, centred around a meeting held in December 2024, and a further meeting in May 2026. The latter meeting was held at the Scottish Government’s request after the course came to the attention of officials through correspondence associated with the passage of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026.
In respect of part 4 of your request we do not hold any documents that include advice, encouragement, endorsement or suggestion in relation to eligibility for the GCU course, you may therefore consider this notice under section 17 of FOISA that such information is not held by the Scottish Government.

The information released in respect of part 5 of the request is as follows:
• Annex A: Records concerning a meeting held between GCU and SG officials on 16 December 2024. N.B. No note of this meeting or follow up exchanges by email have been found.
• Annex B: Records of exchanges between GCU and Scottish Government officials leading to a meeting held on 13 Mar 2026, and material exchanged following that meeting.

This information represents the entirety of exchanges between GCU and officials within the Scottish Government working in the relevant policy area. While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because an exemption under Section 38(1)(b) of FOISA applies. This relates to personal information, and as such redactions have been applied clearly identifying the reason for the redaction. Wherever possible contextual information (such as the domain of email addresses) has been retained to assist understanding of the exchanges. Personal information 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.

Document A3 in Annex A and part of document B5 in Annex B are withheld under s.33(1)(b) of FOISA (commercial sensitivity). Information has been withheld under section 33(1)(b) of the Freedom of Information (Scotland) Act 2002 because disclosure would, or would be likely to, prejudice substantially the commercial interests of one or more parties. Having considered the public interest, we recognise the general public interest in openness and transparency. However, we consider that this is outweighed by the public interest in protecting legitimate commercial interests and ensuring no disadvantage is caused through the disclosure of commercially sensitive information.

Response to your request – Parts 6, and 7

Parts 6, and 7 of your request relate to the Scottish Government’ view on GCU public statements. I can confirm that no public view or statement has been given on these matters and as such the relevant records are to be found contained in internal exchanges and responses to correspondence on this matter, I have enclosed material relevant to these parts of the request. You may also consider that some of the material provided in Annexes A and B is relevant to this question. The information released in respect of these parts of the request is contained in Annex C, which comprises relevant extracts from correspondence with third parties.

While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because an exemption under Section 38(1)(b) of FOISA applies. This relates to personal information, and as such redactions have been applied clearly identifying the reason for the redaction. Wherever possible contextual information (such as the domain of email addresses) has been retained to assist understanding of the exchanges.

Further records were also identified that are not released here. Although our aim is to provide information wherever possible the further records identified are exempt under Section 30(b)(ii) of FOISA. This is because these are records of internal exchanges between officials that informed the subsequent communication with GCU, all of which is being published in this response.

The exemption under Section 30(b)(ii) is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, I have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. I have found that, on balance, the public interest lies in favour of upholding the exemption. I recognise that there is some public interest in release because the comments exempted may provide insight on official considerations that are relevant to your question, although I note that this material does not provide any information on Scottish Government policy not otherwise available. However, this is outweighed by the public interest in ensuring that officials are not inhibited in their ability to exchange views openly before coming to a decision for action. It is also not in the public interest for views of individual officials to be released if there is a risk that they will be interpreted as representative of the wider SG position, especially where the SG position can be understood from other material which is being released. I have reviewed the relevant material carefully and I am comfortable that it is not possible to provide a redacted version of these exchanges, as the whole parts of the exchange that are in scope are subject to the exemption.

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 202600522490 - Information Released - Annex A to C

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