Sample policy · Private clinic

Cosmetic consent and cooling-off period policy (private clinic)

Statutory anchor: Regulation 11 (need for consent), Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (SI 2014/2936). The primary professional sources for cosmetic consent are the GMC guidance for doctors who offer cosmetic interventions and the GMC decision-making and consent guidance; this policy also engages the Mental Capacity Act 2005 and the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021. · primary source

1. What the regulation says

Care and treatment of service users must only be provided with the consent of the relevant person. (Reg 11(1): the headline duty)

The full text of the regulation is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/11. Where this policy and the regulation diverge, the regulation wins.

2. Plain-English summary

You can only provide care or treatment with the consent of the relevant person. If the service user is 16 or over and lacks capacity, follow the Mental Capacity Act 2005. If Parts 4 or 4A of the Mental Health Act 1983 apply, follow that instead. Section 5 of the MCA (acts done in connection with care or treatment) still applies underneath.

3. Purpose

This policy sets out how the Clinic obtains, records and reviews consent for cosmetic and aesthetic procedures.

It covers the two-stage consent process, the cooling-off period, under-18 restrictions for botulinum toxin and fillers, coercion concerns, expectation setting and consent incident response.

4. Sources to verify before adoption

5. Scope

This policy applies to:

The Clinic does not use the word "client" in clinical consent records. The person receiving care is recorded as a patient.

6. Consent process

The Clinic uses a two-stage consent process for cosmetic procedures.

6.1 Stage one: consultation and information

The Consultant or Aesthetic Practitioner completes the first-stage consultation.

The discussion covers:

GMC guidance requires doctors to give patients enough time and information to decide. The Clinic verifies the current wording before adoption and uses this wording as the consent benchmark: "You must give the patient the time and information they need to reach a voluntary and informed decision about whether to go ahead with an intervention."

6.2 Stage two: consent confirmation

The Clinic confirms consent after the cooling-off period.

At the second stage, the clinician:

The clinician performing the procedure normally takes consent. Where another clinician supports the process, the Clinic records why that person was competent to do so and how the treating clinician confirmed consent before treatment.

6.3 Cooling-off period

The Clinic uses 14 calendar days as the Verivius default cooling-off period after first-stage consultation for cosmetic procedures.

The Clinic verifies this against current GMC, RCS and sector guidance before adoption. If the Clinic chooses a shorter period for a lower-risk non-surgical procedure, the Consultant records:

The Clinic does not use same-day discounts, time-limited offers or deposit pressure to shorten reflection time.

7. Under-18 restrictions and safeguarding concerns

The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 states that it is an offence to administer "botulinum toxin" or "a subcutaneous, submucous or intradermal injection of a filler for a cosmetic purpose" where the person "is under the age of 18."

The Clinic does not provide botulinum toxin or dermal fillers to a patient under 18 for a cosmetic purpose.

The Clinic verifies age before consultation booking where the requested procedure may fall within the Act. Staff record:

If an under-18 patient seeks cosmetic treatment, Staff consider whether this is a safeguarding concern, whether coercion is present and whether local safeguarding advice is needed.

8. Capacity, pressure and expectation setting

The Clinic assumes an adult has capacity unless there is reason to assess otherwise.

Staff pause the procedure pathway and seek Consultant review where:

Where capacity is in doubt, the Consultant follows the Mental Capacity Act 2005. The capacity assessment is decision-specific and time-specific.

The Clinic records expectation-setting discussions clearly. Staff do not promise a particular cosmetic outcome.

9. Responsibilities

10. Recording requirements

Each consent record must include the patient, procedure, consultation date, clinician, information and material risks discussed, questions, decision, cooling-off interval, any exception and rationale, final confirmation, withdrawal or refusal and follow-up plan. The Clinic also keeps the following records:

Consent records form part of the clinical record.

10.1 Training and competence

Before taking cosmetic consent without direct supervision, each clinician must be signed off for the procedures they offer. The sign-off covers:

Administration staff receive role-specific training on scheduling and neutral communication. They must not answer clinical consent questions or shorten the reflection period. Completion and practical sign-off are recorded in the training matrix and sampled after a complaint or material consent incident.

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 policies and records

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

14. 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.

15. 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.

16. Document control

Version Date Author Changes
v1 2026-06-10 Verivius (sample) Conformed existing draft to the Verivius policy standard; anchored to Regulation 11; preserved all original sections.
v1.1 2026-07-19 Verivius (sample) Added consent evidence fields, role-specific competency controls and linked companion policies.

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.

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Last reviewed 19 July 2026