Sample policy · Private clinic

Aesthetic procedure safety policy (private clinic)

Statutory anchor: Regulation 12 (safe care and treatment), Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (SI 2014/2936). This policy also engages Regulation 17 (good governance). The primary professional sources for non-surgical aesthetic practice are the GMC guidance for doctors who offer cosmetic interventions, the GMC prescribing guidance, and the MHRA Yellow Card scheme. · primary source

1. What the regulation says

Care and treatment must be provided in a safe way for service users. (Reg 12(1) (the headline duty))

assessing the risks to the health and safety of service users of receiving the care or treatment, (Reg 12(2)(a) (risk assessment))

doing all that is reasonably practicable to mitigate any such risks, (Reg 12(2)(b) (risk mitigation))

ensuring that persons providing care or treatment to service users have the qualifications, competence, skills and experience to do so safely, (Reg 12(2)(c) (staff competence))

where equipment or medicines are supplied by the service provider, ensuring that there are sufficient quantities of these to ensure the safety of service users and to meet their needs, (Reg 12(2)(f) (sufficient equipment + medicines supply))

the proper and safe management of medicines, (Reg 12(2)(g) (medicines management))

The full text is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/12. Where this policy and the regulation diverge, the regulation wins.

2. Plain-English summary

Care and treatment must be provided in a safe way. The regulation lists the areas a provider must address, including risk assessment, risk mitigation, staff competence, safe premises, safe equipment, sufficient equipment and medicines, medicines safety, infection prevention and shared-care planning. Regulation 12 is central to CQC's safety expectations.

3. Purpose

This policy sets out how the Clinic manages safety for non-surgical aesthetic procedures.

It covers botulinum toxin, dermal fillers, product traceability, prescribing routes, anatomical risk review, complication response, Yellow Card reporting and patient selection.

4. Sources to verify before adoption

5. Scope

This policy applies to:

The Clinic does not allow a product, device or medicine to be used unless the Consultant has approved it for the Clinic's service, scope and staff competence.

Before adoption, the Clinic names its clinical and prescribing leads, approved procedures and products, complication and out-of-hours routes, emergency stock locations, photography system, recall owner, referral partners and the records used for treatment, stock, incidents and improvement actions.

6. Aesthetic procedure process

The Clinic follows a documented process for every aesthetic procedure.

6.1 Patient selection

The Aesthetic Practitioner or Consultant assesses:

Where the assessment raises concern, the procedure is paused and the Consultant reviews the patient.

6.2 Product and prescribing checks

The Clinic records the lawful route for each product or medicine.

The check covers:

Staff do not use stock supplied by the patient or by an unapproved supplier.

6.3 Anatomical safety review

Before injection or treatment, the clinician reviews anatomical risks for the treatment area.

The local procedure covers:

The Clinic verifies technique and anatomical protocols against current professional source material before adoption.

7. Complication response

The Clinic keeps a written complication-response pathway.

7.1 Immediate complications

If Staff identify an immediate complication, they:

The Clinic does not treat a complication as a cosmetic dissatisfaction complaint until clinical harm has been excluded.

7.2 Dermal filler vascular concern

The Clinic keeps a filler vascular-event response pathway where it provides dermal fillers.

The pathway covers:

The Clinic verifies hyaluronidase storage, prescribing, dosing and training against current clinical source material before adoption.

7.3 Botulinum toxin adverse event

If a botulinum toxin adverse event occurs, the Clinic records:

The Consultant reviews repeated asymmetry, ptosis, systemic reaction or patient harm trends.

8. Product traceability and recall

The Clinic keeps traceability records for aesthetic products.

Records allow the Clinic to identify every patient treated with a specific product or batch where there is a recall, safety concern or regulatory enquiry.

If a recall or safety alert is received, Staff:

9. Responsibilities

10. Records and evidence fields

For each procedure, the clinical record includes, as applicable:

Product approval, stock, recall, staff competence, audit and improvement-action records form the wider evidence set. The treatment record is cross-linked to these records where needed and is retained under the Clinic's records-management procedure.

11. Audit cadence

The Clinic uses the following Verivius default audit rhythm unless current source material requires a different rhythm:

Audit findings are recorded as improvement actions with an owner and review date.

12. Version control and review date

The Clinic keeps a controlled copy of this policy. The footer or document-control table records:

13. Related records

Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.

14. Related policies and tools

15. Sources and further reading

This template is based on CQC's guidance for providers and managers, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and other topic-specific legislation and guidance listed below. It is a starting point for adaptation, not a substitute for legal, clinical, HR, safeguarding or specialist professional advice.

16. When to seek further advice

Seek specialist advice where the issue involves serious harm, safeguarding, deprivation of liberty, restraint, children, professional misconduct, controlled drugs, radiation, termination of pregnancy, infection outbreak, water safety, employment dismissal, DBS barring referral, or regulatory enforcement.

17. Document control

Version Date Author Changes
v1 2026-06-10 Verivius (sample) Conformed to the Verivius policy standard; existing draft content preserved and renumbered under the standard structure.
v1.1 2026-07-19 Verivius (sample) Added local operating decisions, procedure-level evidence fields, product recall traceability and links to the consent, infection, photography, medicines and emergency controls.

This sample policy template was issued by Verivius. It is a template, not a substitute for legal advice or the provider's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.

What good looks like here

Written from an ex-CQC inspector's chair, but the point is safe, well-led care your team can stand behind. Each row shows what strong evidence looks like, what thin evidence looks like, and where the expectation comes from.

This inspector-check section applies only where the procedure forms part of a CQC-regulated activity. A provider must determine and document which of its services are within its CQC registration. Purely cosmetic non-surgical treatments, including botulinum toxin, dermal fillers and laser or intense-pulsed-light treatments for adults, may fall outside CQC scope even when delivered from the same clinic; botulinum toxin used to treat a disease such as migraine or hyperhidrosis, and surgical or other treatment activities, may fall within it. Non-surgical aesthetics is where prescription-only medicines and injectable products are put into healthy people who walked in by choice, in a market that is only lightly regulated, and the failure that defines it is fast and sometimes irreversible: a dermal filler that occludes a blood vessel can cause skin necrosis or, at the wrong site, loss of vision within minutes. The person in the chair has no way of knowing whether the practitioner can recognise that event, whether the reversal agent is actually in the fridge, or whether the botulinum toxin they are being given was ever prescribed for them by someone who assessed them rather than signed a remote list. That is what the evidence trail protects: a live vascular-occlusion pathway with the rescue stocked and staff trained, a lawful supply route tied to a prescriber who saw this patient, batch traceability that finds everyone treated from a recalled lot, and a positive age check that keeps injectables away from children. Most of this sits below black-letter law and rests on GMC, Joint Council for Cosmetic Practitioners (JCCP) and Cosmetic Practice Standards Authority (CPSA) standards, which is exactly why a provider who can show the records is doing something the market does not yet require of it.

  1. Where the clinic injects dermal fillers, a written vascular-occlusion response is live and rehearsed, so severe pain, blanching, mottled skin or visual symptoms trigger immediate reversal and escalation rather than a wait-and-see callback the next day. Where the fillers are hyaluronic acid, the reversal agent the pathway relies on is actually stocked, in date and ready to hand, with staff trained to recognise the event and act on it, not a protocol that names a rescue the clinic could not perform.

    Strong evidence: The filler vascular-event pathway (recognition signs, immediate senior clinical review, and the emergency referral route including an urgent ophthalmology route for visual symptoms), the emergency-stock check showing in-date hyaluronidase held where hyaluronic-acid fillers are used with its storage log, the practitioner competency records for recognition and reversal, and a dated scenario rehearsal.

    Weak evidence: A pathway that names hyaluronidase as the rescue while the clinic holds none, holds it out of date, or has nobody trained to use it, so the rescue exists only on the page. A filler event recorded as a cosmetic-dissatisfaction complaint before clinical harm was excluded, no named emergency referral route, or visual symptoms with no urgent ophthalmology escalation. The duty to anticipate and mitigate this risk is statutory under Regulation 12; the recognition, storage, dosing and reversal technique themselves come from current clinical source material and the product instructions, and the clinic verifies its protocol against that source, not against this card.

    The recognised standard from a professional or clinical body, such as NICE or a royal college. Not a legal duty, but the accepted mark of safe practice, and a departure needs a documented reason.

  2. Every prescription-only medicine used, including botulinum toxin and any prescription filler or reversal agent, is administered under a lawful supply route tied to a named prescriber who personally assessed this patient, so what goes into a person is a medicine prescribed for them, not stock drawn against a remote list of names or supplied by the patient or an unapproved source.

    Strong evidence: The prescribing record linking each product to the prescriber's identity and professional registration and to a patient-specific assessment, the product-approval list, and the treatment record showing the lawful supply route, product name, batch or lot number and expiry for the item given.

    Weak evidence: A standing list of names a remote prescriber signed against without seeing anyone, botulinum toxin drawn from clinic stock with no prescription traceable to the individual treated, or product the patient brought in or that came from an unapproved supplier. Also weak: a prescriber named on the record whose registration was never confirmed against the live professional register. The lawful-supply duty is statutory and the legal framework is the Human Medicines Regulations 2012; the expectation that the prescriber assess the patient in person rather than remotely is General Medical Council (GMC) prescribing guidance.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 12(2)(g)

  3. Patient selection is a genuine safety gate, not a booking formality, so a person with a contraindication, an active mental-health or body-image concern, signs of coercion or expectations no procedure could meet is paused and reviewed by the consultant before anything is injected, rather than treated because they asked and paid.

    Strong evidence: The patient-selection assessment in the clinical record (reason for treatment, expected outcome, medicines and allergy history, pregnancy or breastfeeding status where relevant, contraindications, signs of pressure or coercion, body-image or mental-health concern and aftercare ability), with the recorded consultant review and outcome wherever the assessment raised a concern.

    Weak evidence: A selection form completed identically for everyone, or the concern fields left blank, so nothing shows this person was actually screened for vulnerability. A treatment that went ahead the same day a body-image or coercion concern was noted, with no consultant pause recorded, or a contraindication flagged in the history that never reached the decision to proceed. The screening and time-for-reflection expectations come from GMC cosmetic-interventions guidance; the underlying duty to assess and mitigate risk to the person is statutory under Regulation 12.

    The recognised standard from a professional or clinical body, such as NICE or a royal college. Not a legal duty, but the accepted mark of safe practice, and a departure needs a documented reason.

  4. The clinic can move in both directions between a batch and a patient: from any product or batch to every person it was used on, and from a person to exactly what was injected into them, so a recall or safety alert can actually reach the affected patients rather than dead-ending in a search through paper that cannot answer who received the batch.

    Strong evidence: The per-patient treatment record carrying product name, batch or lot number and expiry, cross-linked to the product traceability log and the recall log, with a worked example of a recall or Medicines and Healthcare products Regulatory Agency (MHRA) safety alert showing affected stock quarantined, affected patients identified and contacted, and the action recorded.

    Weak evidence: Batch and expiry fields blank or completed only sometimes, a traceability log that lists stock in but never ties it to the patient treated, or a recall notice filed with no evidence anyone checked whether affected product had been used. The clinic can only learn who was exposed by reading back through the appointment diary. Batch-level traceability and recall handling are expected by CQC's safe-management-of-medicines and equipment approach and by MHRA safety-alert handling; the per-patient log format itself is a Verivius mechanic.

    What the regulator expects to see. Not a law in itself, but CQC judges you against it, so an inspector will look for it and expect a reason where you depart from it.

  5. Age is positively verified from acceptable identification and recorded before any cosmetic botulinum toxin or filler injection, so the clinic can show it did not give a cosmetic injectable to a child, rather than relying on a booking form or an impression that the person looked over 18. The clinic's position on under-18s follows the 2021 Act, and where any exception is relied on it is a decision made and recorded by the appropriate registered professional, not a default.

    Strong evidence: The age-verification record showing identity evidence sighted and the date of birth confirmed before any cosmetic injectable, and staff guidance confirming that administering these treatments for a cosmetic purpose to an under-18 in England is a criminal offence and that the professional exceptions are narrow.

    Weak evidence: Date of birth taken from the online booking and never checked against identification, an age field left blank, or reliance on the person appearing over 18, so the control rests on impression rather than evidence. No staff awareness of the offence or of how limited the exceptions are, leaving the clinic unable to show it took reasonable steps to establish age before treating.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, s.1

  6. Complications and adverse events are recorded as clinical events and worked as learning, so a botulinum-toxin reaction, a filler event or a suspected product defect leads to a Yellow Card decision, a consultant review of repeated patterns, and an improvement action that closes, rather than a private word with the patient and nothing written down.

    Strong evidence: The incident register and the MHRA Yellow Card record showing the reporting decision for each event, the consultant's review of trends such as repeated asymmetry, ptosis, systemic reaction or a recurring product concern, and the improvement-action register showing the resulting change owned and closed.

    Weak evidence: Complications discussed at the front desk or quietly refunded but absent from any incident record, so a pattern around one product, one practitioner or one technique never becomes visible. A Yellow Card field left blank with no note of whether a report was made or ruled out, or improvement actions parked at ongoing for months with nothing to show practice changed. Reporting suspected adverse reactions through the MHRA Yellow Card scheme is the expected professional route; the audit cadence that surfaces the trend is a Verivius default, and a Yellow Card report does not discharge a separate CQC statutory notification or a duty-of-candour obligation to the person where those are also owed.

    The recognised standard from a professional or clinical body, such as NICE or a royal college. Not a legal duty, but the accepted mark of safe practice, and a departure needs a documented reason.

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Last verified 23 July 2026

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Last reviewed 19 July 2026