Scottish Government involvement in Glasgow Caledonian University postgraduate aesthetics programme: FOI release

Information requested

You asked for range of records held by the Scottish Government in the context of statements made by Glasgow Caledonian University (GCU) and/or various named individuals concerning their Postgraduate Diploma in Non-Surgical Medical Aesthetics Practice, to demonstrate the Scottish Government’s awareness of or connection to this course. Specifically, you asked:

*Please note that I have numbered the individual requests for ease of reference.

“GCU announced the programme on 18 March 2026. Its announcement stated that the programme had been “developed through consultation with key stakeholders, including the Scottish Government”. Professor Anita Simmers also referred to GCU “working closely with government, clinical experts and professional bodies” when developing the educational pathway.

For the period 1 January 2023 to the date of this request, please provide:

1. Copies of all correspondence, meeting records, notes, briefings, presentations, comments or advice exchanged between the Scottish Government and GCU concerning:

a) the proposal, development, structure or content of the programme;
b) its intended relationship with Scottish legislation or policy;
c) programme entry requirements;
d) eligibility being limited to registered healthcare professionals;
e) education or qualification standards for aesthetic practitioners;
f) clinical placements or supervised practice;
g) Healthcare Improvement Scotland-registered premises; and
h) the announcement, description or promotion of the programme.

2. Copies of all proposals, concept papers, programme outlines, curriculum documents, business cases, draft announcements or other course documents supplied by GCU to the Scottish Government.

3. A list of meetings, discussions or consultation activities involving the Scottish Government and GCU concerning the programme. For each, please provide:

a) the date;
b) the attendees and their organisations or roles;
c) the stated purpose;
d) the matters discussed; and
e) any resulting actions, advice or decisions.

4. Copies of records showing what consultation, information, advice or assistance the Scottish Government provided in connection with the programme’s development.

5. Copies of records concerning GCU’s published statements that:
a) the programme had been “developed through consultation” with the Scottish Government;
b) GCU had been “working closely with government”; and
c) the programme would be open to registered healthcare professionals “outlined in the Scottish Government regulations”.

6. Copies of records showing whether the Scottish Government:

a) was informed before publication that GCU intended to make those statements;
b) reviewed or commented upon any draft announcement;
c) considered those statements accurate;
d) authorised or approved any reference to the Scottish Government;
e) requested any correction, clarification or amendment; or
f) considered whether the announcement might create an inaccurate impression about the legislation or the Government’s involvement.

7. Copies of correspondence and internal records concerning any concern that GCU’s publicity implied that:

a) the Scottish Government had endorsed or supported the programme;
b) the Government and GCU had jointly developed the programme;
c) Scottish legislation excluded independent aesthetic practitioners;
d) the legislation required entry to be restricted to registered healthcare professionals; or
e) the programme’s postgraduate or SCQF level reflected a standard required by Government.

8. Copies of records concerning the Scottish Government’s statement or position that it did not endorse or support the programme, including records distinguishing:

a) consultation from endorsement;
b) engagement from support;
c) the provision of policy advice from participation in course development; and
d) GCU’s independent decisions from matters discussed with Government.

9. Copies of records concerning whether the programme’s healthcare-professional-only entry requirement was discussed with:

a) GCU;
b) the Scottish Medical Aesthetics Safety Group;
c) Jacqueline Cooney;
d) Healthcare Improvement Scotland;
e) NHS Scotland; or
f) any professional body or education provider.

10. Copies of records concerning whether the Scottish Government considered the possible effects of the programme or its entry requirements upon:

a) independent aesthetic practitioners;
b) private aesthetics training providers;
c) prospective students;
d) competition between education providers;
e) workforce access;
f) equality; or
g) businesses affected by the proposed legislation.

*For this request, “independent aesthetic practitioner” means a person who personally performs non-surgical aesthetic procedures and who is not registered as a doctor, dentist, nurse, midwife, pharmacist or another statutory healthcare professional.

11. Copies of all correspondence, meeting records, notes or advice exchanged with the Scottish Medical Aesthetics Safety Group or Jacqueline Cooney concerning:

a) GCU’s programme;
b) its creation or development;
c) its curriculum or entry requirements;
d) clinical placements;
e) Healthcare Improvement Scotland-registered clinics;
f) its relationship with forthcoming Scottish legislation; or
g) its public announcement or promotion.

12. Copies of each version of the legislative explainer or guidance concerning the proposed regulation that was supplied to GCU, together with records showing:

a) when it was prepared;
b) who prepared, reviewed and approved it;
c) when and to whom it was sent;
d) why GCU was selected to receive it;
e) what action or change the Government expected GCU to make;
f) any response received from GCU; and
g) any subsequent change made by GCU.

13. A list of every university, college, private training provider, representative organisation or other external body to which the same explainer, or substantially similar guidance, was supplied. For each recipient, please provide:

a) the date sent;
b) the reason for selection;
c) the covering correspondence; and
d) any response received.

14. Copies of records concerning whether the explainer was made publicly available or supplied to:
a) independent aesthetic practitioners;
b) organisations representing those practitioners;
c) private aesthetics training providers; or
d) businesses likely to be affected by the legislation.

15. Copies of records concerning whether officials considered that giving selected education providers advance or specific guidance about the legislation could confer an informational, educational or commercial advantage.

16. Copies of declarations of interest, conflict-of-interest assessments or recorded consideration of interests relating to any external individual or organisation consulted about the programme or involved in providing clinical placements.”

*This request seeks recorded information that is not otherwise being considered as part of an existing internal review. If any part overlaps information already published or disclosed, please provide the relevant link and identify precisely which part of this request it satisfies

Response

Response to your request – General

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.

Response

Parts 1 to 4 of your request relate to records or exchanges between the Scottish Government and GCU in relation to the development of the programme, and Scottish Government’s involvement. Any information in relation to this can be found in Annex A (sections A1 to A7).

Part 2 of your request relates specifically to any programme business cases or proposals sent by GCU to Scottish Government. This is referenced in Annex A (section A3). Please note that is 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.

As you will see from these documents the Scottish Government has had only limited engagement with GCU, 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.

Any other information you requested in Part 1 to 4 is not held, therefore, please consider this formal notice of that fact under Section 17 of FOISA.

Parts 5 and 6 are in relation to public statements surrounding programme’s promotion and the Scottish Government. Information relating to this can be found in Annex A (sections A7 to A14). Any other information you request in Parts 5 and 6 is not held, therefore, please consider this formal notice of that fact under Section 17 of FOISA.

Parts 7 and 8 relate to any records held on any concern by the Scottish Government on its perceived association with the programme. Any information held on this can be found in Annex A (section A14).

Any other information you request under Parts 7 or 8 is not held, therefore, please consider this formal notice of that fact under Section 17 of FOISA.

In regard to Part 9 of your request, searches located no records showing that the healthcareprofessional-only entry requirement was discussed with the organisations or individuals listed. This is formal notice this information is not held under Section 17 of FOISA.

Part 10 of your request is in relation to records held on Scottish Government’s position on the effects of the programme, or its entry requirements. This is formal notice this information is not held under Section 17 of FOISA.

Searches identified no communications between Scottish Government and SMASG or Jacqueline Cooney concerning the specific matters listed in Part 11. This is formal notice this information is not held under Section 17 of FOISA.

Part 12 of your request relates to the document, Explainer – NSP Act – Practitioners and Settings, which can be seen in Annex A (section A6). In response to each of your requests, I can update on the following:

a. The document was prepared between 12-20 May 2026.
b. The document was prepared, reviewed, and approved by the Quality and Safety policy team under the Healthcare Quality and Improvement Division at Scottish Government
c. It was sent to GCU on 27 May 2026, as referenced in Annex A (section A5). Recipient’s names are redacted under Section 38(1)(b))
d. This information is not held
e. This can be found in Annex A (section A5). Recipient’s names are redacted under Section 38(1)(b))
f. No information is held.
g. There is no information held of any change to the ‘Explainer – NSP Act – Practitioners and Settings’ document following the email to GCU on 27 May 2026.

Where information is not provided above, this is formal notice this information is not held under Section 17 of FOISA.

In relation to Part 13 of your request, in addition to sending the Explainer – NSP Act – Practitioners and Settings document, via email, to CGU, as referenced in Annex A (sections A5 and A6). This was also sent to Healthcare Improvement Scotland (HIS) (see Annex A (section A15)) and the University of the West of Scotland (see Annex A (section A16)). Where information is not provided, this is formal notice this information is not held under Section 17 of FOISA.

In response to Parts 14, 15 and 16 of your request, this formal notice this information is not held under Section 17 of FOISA.

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 202600529339 - Information Released - Annex A

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