Training and experience
Always work within your area of competence and be prepared to refer patients if you don’t have the training and experience to carry out a procedure safely.
If you intend to carry out non-surgical cosmetic treatments, such as botulinum toxin injections, ensure you meet the qualification requirements for practitioners set by Health Education England.
Keep your knowledge and skills up to date. In Professional standards for cosmetic surgery, the Royal College of Surgeons sets out minimum requirements for continuing professional development (CPD) which should 'include communication skills and a basic understanding of psychological processes, with specific reference to body image disturbance’.
Familiarise yourself with relevant guidance, such as the professional codes of practice produced by the BAAPS and BAPRAS.
Keep the MDU informed about the type of work you are doing so we can ensure you are appropriately indemnified.
Do not provide cosmetic treatment if you do not believe it will deliver the desired outcome or be of overall benefit to the patient, even if there is a risk they go to another practitioner.
Take particular care with young patients and encourage them to involve their parents, even if they have capacity. If a young patient lacks capacity, someone with parental responsibility can consent on their behalf. However, you should involve the patient as much as possible and must not proceed if you do not believe the treatment is in their best interests or they are reluctant.
You must not prescribe non-surgical cosmetic medicinal products without having first examined the patient.
Obtaining the patient's fully-informed and voluntary consent is an ethical duty and helps to avoid misunderstandings in cosmetic practice. When seeking consent for cosmetic procedures you should:
- Discuss the procedure with the patient yourself, rather than delegating the task.
- Give the patient all the information they need about a procedure, including the risk of complications or an adverse outcome, any necessary follow-up care and less risky alternatives. Be mindful of their expectations and try to address them.
- Consider the patient’s vulnerabilities and psychological needs.
- Give patients plenty of time to reflect and where necessary seek an expert opinion so they can reach an informed decision.
- Clearly explain charges so the patient understands what is included and what other costs may be payable, such as follow-up appointments.
- Fully document the consent discussion in the patient’s records.
- Bear in mind that consent is not a one-off; tell the patient they can change their mind at any point and be ready to answer further questions.
Marketing cosmetic services
Your marketing material must be factual, verifiable and must not make unjustifiable claims about quality or outcome. The GMC specifically prohibits promotional competitions to ‘win’ cosmetic treatments and other promotional tactics that could encourage people to make an ill-considered decision.
The material must comply with the Committee of Advertising Practice (CAP) Code. CAP has also produced guidance on the marketing of cosmetic procedures, which covers before and after photographs, testimonials and financial products.
Prescription-only medicines (POMS), such as botulinum toxin, cannot be advertised directly to the general public under the Human Medicines Regulations 2012.
Quality assurance and safety
The CQC regulates cosmetic treatments 'that involve any instrument or equipment being inserted into the body'– including breast enlargements, laser eye surgery, nose surgery and facelifts. In order to provide these services, the location offering them must be CQC-registered.
You must carry out cosmetic interventions in a safe environment that is properly equipped and staffed.
Be honest and open with patients when something goes wrong, in line with your duty of candour.
Ensure it is possible to identify patients who have received a particular implant or medicine, should a safety concern be identified at some point in the future. In October 2016, NHS Digital launched a Breast and Cosmetic Implant Registry (BCIR) to capture details of all breast implant procedures in England. NHS and private providers will be expected to submit data with patients’ consent.
Give the patient written discharge information, including the specific device used and copy this to their GP, with the patient’s consent.
Audit your practice, regularly ask for feedback from patients and colleagues and contribute to national programmes to monitor quality and outcomes.
Report product safety concerns to the Medicines and Healthcare products Regulatory Agency (MHRA) or its equivalent.
This guidance was correct at publication 20/11/2017. It is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.