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 stage of consent is recorded in the clinical record by the clinician responsible for the procedure. The consent record should include:

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
v1.2 2026-07-21 Verivius (sample) Expanded the two-stage consent record to evidence alternatives, patient-specific risks, information versions, cooling-off and final confirmation.
v1.1 2026-07-19 Verivius (sample) Added consent evidence fields, role-specific competency controls and linked companion policies.
v1 2026-06-10 Verivius (sample) Conformed existing draft to the Verivius policy standard; anchored to Regulation 11; preserved all original sections.

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.

Cosmetic practice is one of the few clinical settings where the person asking for treatment is also a paying customer, and where the decision is elective, appearance-driven and often shaped by how someone feels about themselves that week. That is the clinical work the reflection gap actually does: a patient who is grieving, in a controlling relationship or fixated on a single feature frequently presents differently at the second-stage conversation than they did in the room the first time, and the pause is what surfaces it. Botulinum toxin wears off within months, but a vascular occlusion, filler that will not dissolve cleanly, a moved hairline or a scar from cosmetic minor surgery can be permanent, and a person who felt hurried lives with the result and with the memory of being hurried. A consent trail that shows two dated conversations, what was genuinely said about limitations and alternatives, and what happened when someone hesitated, is what allows the Consultant to defend a decision to decline as confidently as a decision to treat. Age verification sits in the same trail for a different reason: administering botulinum toxin or a subcutaneous, submucous or intradermal injection of a filler for a cosmetic purpose to someone under 18 is an offence, so that control has to work at the booking desk, not at the treatment couch.

  1. Consent is built across two dated stages with a reflection gap between them, not a single signature on the day. Where the two stages collapse into one visit, the patient hears the risks and agrees to them in the same conversation.

    Strong evidence: First-stage consultation note, a recorded cooling-off period start date and a separate second-stage consent confirmation held in the clinical record (sections 6.1, 6.2, 10).

    Weak evidence: One consent form signed on the day of treatment, with the consultation note and the consent signature carrying the same date, so no reflection gap can be shown to have existed. Or a first-stage note that reads well but records no cooling-off start date, so the clinic cannot say when the patient's thinking time began or ended.

    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. The cooling-off period is protected from commercial pressure, and any shortened interval is a recorded, authorised exception rather than routine. Where commercial pressure wins, a patient is treated the same day because a time-limited offer or a deposit made waiting feel costly.

    Strong evidence: Cooling-off exception record naming why the shorter interval was clinically and ethically appropriate, the information given, how the patient had time to reflect, that there was no pressure and who authorised it, reviewed in the monthly audit of cooling-off exceptions; the policy bars same-day discounts, time-limited offers and deposit pressure (sections 6.3, 11).

    Weak evidence: A cooling-off exception recorded as "patient keen to proceed" or "patient requested an earlier date", with no clinical or ethical reason, no named authoriser and nothing showing how the patient still had time to reflect. Or a monthly review in which shortened intervals outnumber the standard ones, while the clinic's own advertising is still running time-limited offers and non-refundable deposits.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  3. Under-18 requests for botulinum toxin or fillers are screened out before booking, with age actively verified. Where age is never actively checked, a young person is consulted, quoted and booked on whatever date of birth was typed into a booking form.

    Strong evidence: Age-verification record showing date-of-birth check, identity evidence checked, procedure requested and whether it involved botulinum toxin or a filler, plus any safeguarding concern raised, under the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 (section 7).

    Weak evidence: Age taken from whatever the patient typed into the online booking form, with no identity evidence seen and no record that anyone checked. Or a screening step that only bites in the treatment room, after a young person has already been consulted, quoted and booked for botulinum toxin or filler, and with no note of whether the request itself raised a safeguarding concern.

    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 (administering to a person under 18 in England for a cosmetic purpose) and s.2 (business making arrangements for or booking such an appointment)

  4. Consent is confirmed by the clinician performing the procedure, or by a delegate whose competence is recorded, not collected by administrative staff. Where reception collects the form instead, the patient signs and no clinician confirms the decision with them before treatment begins.

    Strong evidence: Clinician name and role on the consent record; where another clinician supports the process, a record of why that person was competent and how the treating clinician confirmed consent before treatment (section 6.2).

    Weak evidence: A consent form collected and filed at reception before the treating clinician has seen the patient that day, with the clinician's name pre-printed rather than any record of them confirming the decision. Or a supporting clinician's name on the form with nothing showing why that person was competent to take cosmetic consent and no evidence the treating clinician reconfirmed it before starting.

    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.

  5. Signs of coercion, impaired capacity or unrealistic expectation pause the pathway and reach the Consultant, rather than being noted and worked around. Where the pathway carries on regardless, a patient under pressure from someone else, or expecting an outcome that cannot be delivered, is treated anyway.

    Strong evidence: Coercion or pressure concern record and, where capacity is in doubt, a decision-specific and time-specific Mental Capacity Act 2005 assessment, with expectation-setting discussions recorded and no promised outcome (sections 8, 10).

    Weak evidence: Notes that mention a partner answering the questions, or a patient pressing for a further treatment to the same area against advice, and then continue straight to booking with no pause and no Consultant review. Or a capacity line reading "has capacity" as a standing statement, with no decision-specific and time-specific assessment behind it, sitting alongside outcome talk that has drifted into reassurance.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  6. Clinicians are signed off before taking cosmetic consent unsupervised, and administrative staff keep to scheduling and neutral communication. Where sign-off is assumed rather than assessed, an unassessed practitioner takes consent, or reception answers a clinical question and brings an appointment forward, cutting the patient's reflection time.

    Strong evidence: Training-matrix sign-off covering the two-stage workflow, procedure-specific risks, under-18 restrictions and recognising pressure or impaired capacity, sampled after a complaint or material consent incident (section 10.1).

    Weak evidence: A training matrix with a tick against "consent" and a date, but nothing showing the practitioner was observed taking cosmetic consent or assessed on procedure-specific risks, under-18 restrictions and recognising pressure. Or administrative staff answering "is filler safe for someone like me?" by email and offering to bring an appointment forward, with no sampling of those exchanges after a consent complaint.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

Related

Last verified 20 July 2026

Spotted something to improve?

These are sample templates, not the last word. If you would change a wording, or want to help us confirm a detail, tell us and we will look at it.

Related Verivius content

Want help adapting this to your service?

A Verivius consultant can read your adapted policy against the live regulation and your service shape. The work fits inside a Mock Inspection engagement or a shorter consulting brief. A 20-minute conversation is the fastest way to find out whether the fit is right.

Get started free

Free to start, no card. A 14-day trial when you subscribe.

Last reviewed 21 July 2026