1. 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.
2. Sources to verify before adoption
- GMC, Guidance for doctors who offer cosmetic interventions: https://www.gmc-uk.org/professional-standards/the-professional-standards/cosmetic-interventions
- GMC, Decision making and consent: https://www.gmc-uk.org/professional-standards/the-professional-standards/decision-making-and-consent
- Royal College of Surgeons of England, Professional Standards for Cosmetic Surgery: https://www.rcseng.ac.uk/standards-and-research/standards-and-guidance/service-standards/cosmetic-surgery/professional-standards-for-cosmetic-surgery/
- Botulinum Toxin and Cosmetic Fillers (Children) Act 2021: https://www.legislation.gov.uk/ukpga/2021/19/contents
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 9: https://www.legislation.gov.uk/uksi/2014/2936/regulation/9
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 12: https://www.legislation.gov.uk/uksi/2014/2936/regulation/12
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 17: https://www.legislation.gov.uk/uksi/2014/2936/regulation/17
- Mental Capacity Act 2005: https://www.legislation.gov.uk/ukpga/2005/9/contents
- Department of Health, Review of the Regulation of Cosmetic Interventions: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/192028/Review_of_the_Regulation_of_Cosmetic_Interventions.pdf
3. Scope
This policy applies to:
- cosmetic consultations
- botulinum toxin procedures
- dermal filler procedures
- cosmetic dermatology procedures
- hair restoration procedures
- minor surgical procedures where the purpose is cosmetic
- follow-up consultations after cosmetic procedures
- patients seeking procedures after advertising, social media, referral or repeat attendance
- clinicians, aesthetic practitioners, nurses and administrative staff involved in consent scheduling
The Clinic does not use the word "client" in clinical consent records. The person receiving care is recorded as a patient.
4. Consent process
The Clinic uses a two-stage consent process for cosmetic procedures.
4.1 Stage one: consultation and information
The Consultant or Aesthetic Practitioner completes the first-stage consultation.
The discussion covers:
- the patient's reasons for seeking the procedure
- intended benefit
- realistic outcome
- material risks
- common side effects
- rare but serious complications
- alternatives, including no procedure
- likely recovery time
- aftercare requirements
- cost and refund terms
- product, device or medicine to be used
- whether the procedure is reversible
- who will perform the procedure
- who will provide follow-up care
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."
4.2 Stage two: consent confirmation
The Clinic confirms consent after the cooling-off period.
At the second stage, the clinician:
- checks the patient still wants the procedure
- checks whether circumstances have changed
- checks whether the patient has new questions
- confirms the procedure, product, treatment area and expected outcome
- confirms the patient understands the risks and limitations
- records the consent decision
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.
4.3 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:
- why the shorter interval was clinically and ethically appropriate
- what information the patient received
- how the patient had time to reflect
- why there was no pressure to proceed
- who authorised the exception
The Clinic does not use same-day discounts, time-limited offers or deposit pressure to shorten reflection time.
5. 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:
- date of birth check
- identity evidence checked
- procedure requested
- whether the request involved botulinum toxin or a filler
- safeguarding concern raised where relevant
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.
6. 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:
- the patient appears unable to understand or weigh information
- the patient appears to be under pressure from another person
- the patient describes distress, unrealistic expectations or body image concern
- the patient asks for repeated escalation of treatment against clinical advice
- the patient appears to expect a guaranteed outcome
- the consultation raises domestic abuse, exploitation or adult-at-risk concerns
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.
7. Responsibilities
- Registered Manager: owns this policy, ensures consent governance is reviewed and signs off annual review.
- Consultant: owns clinical consent standards, approves exceptions to the default cooling-off period and reviews complex cases.
- Aesthetic Practitioner: completes cosmetic-procedure consent within role and competence, records product-specific discussions and escalates pressure or capacity concerns.
- Clinic Nurse: supports clinical observations, aftercare checks and patient information where within competence.
- Administration staff: schedule consultations and procedures in line with the cooling-off process. They do not pressure patients to proceed.
- All staff: report consent concerns, coercion concerns and under-18 cosmetic-procedure requests.
8. Recording requirements
The Clinic keeps the following records:
- first-stage consultation note
- patient information provided
- procedure-specific consent form
- cooling-off period start date
- second-stage consent confirmation
- age verification where relevant
- capacity assessment where relevant
- coercion or pressure concern record
- product, batch and treatment area record
- clinician name and role
- consent exception rationale
- refusal or withdrawal of consent
- follow-up and aftercare record
- complaint or incident record where consent is challenged
Consent records form part of the clinical record.
9. Audit cadence
The Clinic uses the following Verivius default audit rhythm unless current source material requires a different rhythm:
- Monthly: the Registered Manager reviews cancelled procedures, consent complaints and cooling-off period exceptions.
- Quarterly: the Consultant audits cosmetic consent records, under-18 screening and patient expectation documentation.
- Annually: the Clinic reviews this policy against current GMC, RCS, CQC and statutory source material.
Audit findings are recorded as improvement actions with an owner and review date.
10. Version control and review date
The Clinic keeps a controlled copy of this policy. The footer or document-control table records:
- policy owner
- version number
- date approved
- next review date
- changes made since the last version
- source material checked during the review
11. Related records
- Consent form
- Cosmetic consultation template
- Cooling-off exception record
- Safeguarding policy
- Mental Capacity Act record
- Complaint register
- Incident register
- Aesthetic procedure safety policy
- Before-and-after photography and data protection policy
- Improvement action register
Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.