FOI Request - Advanced Electrolysis, Blemish Removal and Licensing Position

Request 101004016147

This request concerns your Council’s position on advanced electrolysis, thermolysis, electrocautery, advanced cosmetic procedures, blemish removal, skin lesion removal, and the relationship between those treatments and skin piercing, tattooing or non-surgical procedures licensing.

For the period 1 January 2020 to the date of this request, please provide the following recorded information:

1. Any policy, guidance, internal instruction, procedure note, legal advice summary, officer briefing, meeting note, email, training material or other recorded information held by the Council concerning whether advanced electrolysis, thermolysis, electrocautery, advanced cosmetic procedures, blemish removal, or skin lesion removal is covered by, or excluded from, a skin piercing and tattooing licence.

2. Any recorded information showing the Council’s current position on whether advanced electrolysis blemish removal is:

a) covered by an existing electrolysis or skin piercing and tattooing licence
b) permitted but not licensable under the current local authority licensing framework
c) outside the scope of the existing licence regime
d) subject to a different licensing category
e) or expected to fall within Group 1, Group 2, Group 3, or another category under the incoming Scottish non-surgical procedures licensing framework

3. Any recorded information showing whether the Council’s interpretation of advanced electrolysis blemish removal has changed since 1 January 2020 and, if so, the recorded reason for that change, who approved it, and whether licence holders or practitioners were notified.

4. Any recorded information showing the specific statutory provision, licence condition, written policy, internal guidance, legal advice summary or officer instruction relied upon for the Council’s current position in relation to advanced electrolysis blemish removal.

5. Any communications, including emails, letters, meeting notes, attachments, Teams messages or briefing notes, between the Council and any of the following bodies concerning advanced electrolysis, thermolysis, electrocautery, advanced cosmetic procedures, blemish removal, skin lesion removal, skin piercing licensing, non-surgical cosmetic procedure licensing, or practitioner categorisation:

a) Scottish Government
b) Healthcare Improvement Scotland
c) REHIS
d) SOLAR
e) CIEH
f) JCCP
g) Scottish Cosmetic Interventions Expert Group
h) any other Scottish local authority
i) any professional or trade body concerned with electrolysis, beauty therapy, aesthetics or non-surgical procedures

6. For item 5(f), please include any correspondence, attachments, meeting notes, briefing notes, guidance, presentations, reports or other recorded information exchanged with, sent to, received from, or referring to the JCCP, where the subject matter included advanced electrolysis, electrolysis, blemish removal, skin lesion removal, electrocautery, non-surgical cosmetic procedure licensing, practitioner eligibility, practitioner categories, or the distinction between healthcare professionals and non-healthcare practitioners.

7. Any recorded information showing whether JCCP material, guidance, correspondence, presentations, reports, website material, meetings or advice have been relied upon by the Council when forming, reviewing, applying, or communicating its position on advanced electrolysis, blemish removal, skin lesion removal, or non-surgical cosmetic procedure licensing.

8. Any recorded information showing whether the Council has considered the Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026 in relation to advanced electrolysis or electrocautery blemish removal.

9. Any recorded information showing how the Council is applying, interpreting, preparing for, or advising practitioners about the 2026 non-surgical procedures licensing framework before the relevant commencement date.

10. Any recorded information showing whether advanced electrolysis blemish removal has previously been accepted, discussed, inspected, disclosed, recorded, or considered as part of electrolysis licence applications, renewals, inspections or officer visits in your local authority area.

11. Any recorded information showing how many practitioners, salons or clinics in your local authority area currently hold, or have held since 1 January 2020, a skin piercing and tattooing licence where electrolysis, advanced electrolysis, advanced cosmetic procedures, blemish removal, or similar wording was included in the application, renewal paperwork, inspection record, or related correspondence.

12. Any recorded information showing the standards, protocols, guidance, inspection criteria or written framework that the Council expects advanced electrolysis blemish removal practitioners to meet under the Health and Safety at Work etc. Act 1974.

13. Any recorded information showing whether the Council has sought legal advice, internal or external, on whether advanced electrolysis blemish removal is covered by current electrolysis or skin piercing licensing.

14. Any recorded information showing whether licence fees have ever been considered for refund, review, reassessment, or reimbursement where a practitioner paid for an electrolysis or skin piercing licence and was later advised that advanced electrolysis blemish removal was not covered by that licence.

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