_SECTION
THREE

In this chapter:

Our work with the Advertising Standards Authority

_{Advertising and social media}

^{Our work with the Advertising Standards Authority}

Throughput the reporting year the JCCP has continued to witness a further (and significant) increase in the number of exaggerated, untruthful and false advertisements that are posted on social media. We are also continuing to see gross misrepresentation of the benefits of treatment, understatement of the risks and exaggerated and false claims relating to the provision of education and training. The JCCP has therefore worked very closely with the Advertising Standards Authority and contributed to the development Government’s ‘Online Safety Act, 2023’ to seek to reduce the number of inaccurate, exaggerated and potentially harmful advertisements on social media postings regarding nonsurgical cosmetic procedures and the posting of advertisements that offer education and training to practitioners that do not meet the standards required to equip practitioners with the educational knowledge and competencies to enable to practise safely and proficiently.

The JCCP has formed an excellent partnership with the Advertising Standards Authority to share reports relating to unacceptable and illegal forms of advertising. The ASA continues to respond on a regular basis to multiple complaints raised by the JCCP by publishing many new rulings that will affect both registered healthcare practitioners working in aesthetic practice and lay practitioners.

The JCCP has also continued to identify and report those education and training providers who profess to offer qualifications and training programmes that do not reflect the standards to deliver safe and competent aesthetic treatments. This has been the subject of a key JCCP campaign working alongside the Advertising Standards Authority (ASA) to respond to inaccurately or exaggerated claims promoted and advertised by some unregulated education and training organisations. Over 80 such companies have been reported to the ASA this year and are subject to ongoing investigation. This remains a very active component of this campaign.

JCCP CAG Committee

^{Clinical Advisory Group activities}

The JCCP’ Clinical Advisory Group (CAG) has continued to meet throughout the year in a bi-monthly basis under the joint Chairmanship of Dr. Paul Charlson and Andrew Rankin. The key aim of the CAG has been to work alongside the CPSA to inform, adopt and promote practice standards for the non-surgical and hair restoration sector. The CAG has also provided a forum to support clinical leadership, advice, scrutiny, and challenge with regard to clinical practice related matters to the JCCP Trust Board. In particular the CAG has again:

Championed clinical excellence for patients and members of the public.
Advised on clinically related professional healthcare aspects of operating the JCCP Registers.
Provided clinical advice and oversight in relation to JCCP policies and activities.
Provided an overarching forum to co-ordinate discussion and to formulate opinion on matters relating to the use, supply and administration of safer products/medicines, the provision of standards and systems of inspection for safer premises and safe working practices.
Assisted the JCCP in the formulation of any new policies that require a clinical input and focus.
Raised and responded to major issues of clinical concern on operational performance within the cosmetic sector.
Advised on and supported the development of solutions to current and emergent clinical issues.
Advised on compliance requirements relating to legal, policy and regulatory frameworks of practice within the four countries of the UK.
Responded to and advised on clinically related enquiries from the media, government agencies, members of the general public or practitioners.
Provided an advice to both the MHRA and to the CQC on key issues relating to aesthetic practice and future regulation.
Led on the formulation of guidance to inform the DHSC consultation on procedures to be included in the scope of the new Practitioner licence.
Developed guidelines on ‘supervision’ and ‘oversight’.
Advised on matters relating to the holding of stock medication and remote prescribing.
Formulated guidelines on breast and buttock augmentation (as advised previously in this report.

The Clinical Advisory Group (CAG) includes engagement with the CQC, the MHRA, the British Beauty Council, BABTAC, Habia, The Chartered Institute for Environmental Health, Regulators, Global and National Pharma and Pharmacy companies and other key stakeholders to consider and advise on matters that pertain to the design of a licensing scheme for the aesthetics sector in England. Whilst this group has no regulatory intent or remit it has developed strong relationships with regulators and with stakeholders, providing the opportunity for eclectic debate and discussion to inform future deliberations and direction on this subject. The Clinical Advisory Group continues to work on the messaging required to ensure the appropriate and ethical supply of medicines, products, devices and machines. It is the JCCP’s belief that members of the public should have access to the knowledge required to confirm that they are receiving safe and regulated products from designated and approved suppliers.

Once again, this year the JCCP has worked with several Professional Statutory Regulators (the General Medical Council, the General Dental Council, the Nursing and Midwifery Council, the General Pharmaceutical Council and the Royal Pharmaceutical Society) to seek their uniform endorsement of the JCCP and CPSA’s decision not to endorse or permit the remote prescribing of any prescription medicine when used specifically for non-surgical cosmetic treatments.

Throughout 2024 the JCCP has worked with other stakeholders to reinforce the need for all Professional Statutory Professional Regulatory Bodies (PSRBs) to align their policy position regarding the need for a face-to-face consultation to be undertaken whenever a prescription only medicine is prescribed for an elective non-surgical procedure. The JCCP remains firm in its position on this matter and has engaged with all relevant responsible (PSRBs) to promote its guidance statement on ‘Responsible Prescribing for Cosmetic Procedures’ (September, 2022). (The guidance can be found on the JCCP website). The Nursing and Midwifery Council issued a policy statement in January, 2025 to advise its Independent Prescriber Registrants of the need to desist from remote prescribing for elective cosmetic procedures. The JCCP played a most active role in achieving this position.

CAG also enjoys an excellent collaborative partnership with colleagues at the CQC.

The JCCP’s Memorandum of Understanding with the MHRA was renewed again in 2024 and is transacted through the MHRA’s active membership of CAG. The JCCP’s Key Opinion Leaders are also invited members of the JCCP’s Clinical Advisory Group. CAG also enjoys an excellent collaborative partnership with colleagues at the CQC.

The JCCP is continues to work with the CPSA to identify a range of emergent treatment modalities/procedures which are regarded to have a proportionate degree of risk associated with their transaction (e.g., Platelet Replacement Therapy). The CPSA and the JCCP will explore options to develop new practice and educational standards for these procedures in support of the proposed licensing/governance schemes proposed for both England and Scotland over the next two years.
The JCCP has enjoyed an excellent working relationship again this year with the British College of Aesthetic Medicine (BCAM) through the medium of a shared Memorandum of Understanding. The JCCP also welcomed Dr. Elaine Sassoon as a newly appointed Trustee to the JCCP Board as an official representative of BAAPS (The British Association of Aesthetic Plastic Surgeons’. The Royal College of Surgeons has also been engaged as a most valued and active partner throughout the year, supporting the JCCP in drafting guidance on both non-surgical and cosmetic surgical procedure. This alliance will continue throughout 2025 as part of our shared commitment to co-designing new standards to inform national schemes of licensing and governance for the sector in England and Scotland.

The JCCP’s partnership with the Royal College of Public Health (RSPH) has also continued throughout the year with an emphasis on health protection and infection control standards and online training. RSPH representatives were appointed as members of the JCCP Education and Training Task and Finish Group’s review of current and future education and training standards for the sector.

The JCCP also developed a new partnership agreement in 2024 in the form of a Memorandum of Understanding with the British Association of Hair Restoration Surgery (BAHRS). The JCCP had agreed the following definition of Hair restoration Surgery with BAHRS ‘The JCCP includes Hair Restoration Surgery (HRS) within its list of approved procedures for which national practice, education and training standards have been set in association with the Cosmetic Practice Standards Authority (CPSA) . Whilst Hair Transplant Surgery (HTS) is not listed in Category 3 of the Consultation Document, the JCCP is of the opinion that HTS should be considered a surgical procedure and that the surgical steps of the procedure must only be performed by a GMC licensed doctor. The JCCP is also of the opinion that HRS should be subjected to CQC/HIS/HIW/RQIA regulatory control.’

The JCCP recognises that there are major issues associated with the lack of data and substantive research relating to the cosmetic sector. There are many small studies available but there is no coordinated national framework to collect data on the sector or to develop a considered evidence based research programme. The JCCP has again commissioned research programmes this year in key areas relating to patient safety which have been supported by its corporate partners. The JCCP recognises that our research programmes require further investment and scaling up if we are to contribute meaningfully to provide substantive evidence to practitioners, stakeholders, and government to influence policy change. The reason for this is clear. The non-surgical cosmetic sector has grown rapidly and is a sector where new treatments are emerging exponentially. The JCCP is well positioned to act as a coordinating or overarching body to review and consider emergent research needs and trends within the aesthetics sector and as a charity the Council is able receive grants and funds in furtherance of public protection and patient safety aims. It is therefore proposed that this is an area that can be further developed in 2025 in partnership with our corporate members and stakeholders.

The JCCP CAG also recently published guidelines for the reporting of adverse incidents. This guidance statement acts as a reminder to all regulated healthcare cosmetic practitioners of their professional obligations in reporting adverse incidents. It also serves to highlight the ethical responsibility that unregulated practitioners have in doing the same. This statement concerns the reporting of both medicines and medical devices of all types that fall within the remit of the Medicines Healthcare products Regulatory Agency, and where facility is provided through its Yellow Card scheme to enable such reporting. The Statement may be viewed here. The JCCP considers that an improved data set of adverse incidents will inform the ongoing development of regulations within the sector (including the design of the new proposed licensing standards and framework). We therefore encourage all practitioners to review this paper and to follow the guidance it provides.