Obtain informed consent from patients.
Ensure you are appropriately trained, experienced and indemnified.
Market your services responsibly.
Follow the GMC's 'Guidance for all doctors who offer cosmetic interventions'.

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.

Remember, if you're not yet on the GMC specialist or GP register and have not yet had your first revalidation, your GMC registration restricts you to working in an approved practice setting. You need to have a connection with a designated body, and if you want to work outside your training, speak with your educational supervisor.

The Cosmetic Practice Standards Authority sets standards for non-surgical cosmetic treatments. Those who meet the standards can join the voluntary register run by the Joint Council of Cosmetic Practice.

Keep your knowledge and skills up to date. The Royal College of Surgeons sets out minimum requirements for continuing professional development (CPD) in 'Professional standards for cosmetic surgery', 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 full scope of work you are doing and ensure you're appropriately indemnified.

Patient assessment

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.

You must not prescribe non-surgical cosmetic medicinal products without having first examined the patient.

Consent

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 must follow both the GMC's 'Decision making and consent' guidance and its specific guidance on cosmetic interventions, which states that you must do the following.

Discuss the reasons for the request, the outcome the patient is hoping for and the proposed procedure with the patient yourself; do not delegate the task.
Consider the patient's vulnerabilities and psychological needs and satisfy yourself that it is their own, voluntary request for cosmetic intervention.
Explore with the patient what risks they would and wouldn't be prepared to take to achieve the desired outcome, and how the likelihood of a particular outcome might influence their choice.
Give the patient all the information they need about a procedure, clearly and accurately, including the risk of complications or an adverse outcome (including any risk of serious harm), any necessary follow-up care and less risky alternatives.
Be mindful of their expectations and try to address them. You must talk to the patient about any adverse outcomes that may happen and the potential impacts (physical and psychological) if the procedure goes wrong or if the outcome does not meet their expectations.
Give patients plenty of time to reflect and, where necessary, seek an expert opinion so they can reach an informed decision.
Consider if you need to consult the patient's GP to inform the risk/benefit discussion. If the patient refuses to allow this, you must record it in the notes and weigh this into your risk/benefit analysis before you decide whether to go ahead.
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; you must tell the patient they can change their mind at any point and be ready to answer further questions.

Under-18s in England

The Botulinum Toxin and Cosmetic Fillers (Children) Act came into force on 1 October 2021. It aims to safeguard children from the potential health risks associated with botulinum toxin (commonly known as Botox) and cosmetic fillers.

The law applies not only to businesses but also to providers of clinical healthcare services and regulated medical practitioners.

It is a criminal offence to administer cosmetic fillers to those under the age of 18.
Permission to go ahead with treatment cannot be provided by someone with parental responsibility for the child.
It is also an offence to book appointments or make arrangements to provide treatment to anyone under the age of 18 in England.

Definitions of cosmetic purposes are set out in the Act and include any substances inserted into the body with the intention of producing a filling effect to change appearance.

An exception to the law is where treatment is provided to under-18s to meet a named clinical need when administered by a registered doctor, nurse, dentist or pharmacist, having been approved by a registered medical practitioner.

The only other exception providing a defence is where the provider takes reasonable steps to establish the patient's age, and reasonably believed they were 18 or over.

If you're asked to provide a cosmetic intervention for anyone under 18, or who lacks mental capacity, please contact us for advice.

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.
Make sure it's possible to identify patients who have received a particular implant or medicine in case a safety concern is 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.

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