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Premises and licensing

Checking a clinic in Scotland: Healthcare Improvement Scotland

Premises11 min read
A watermark visible only when the sheet is held up. Scope is what you see when you look through the scheme.

A watermark visible only when the sheet is held up. Scope is what you see when you look through the scheme.

The short answer

Independent clinics in Scotland providing services by certain regulated healthcare professionals must register with Healthcare Improvement Scotland, which inspects them and publishes reports. The scope is not identical to England, so a service unregistered south of the border may require registration in Scotland. Search the register by service name and address, read which service type is registered, and read the inspection report rather than any summary of it.

Scotland diverges from England here in a way that genuinely matters to patients, and the divergence is not widely understood on either side of the border. If you are treated in Scotland, the English answer is the wrong answer.

The basis of the Scottish scheme

Healthcare Improvement Scotland regulates independent healthcare services in Scotland. The category includes independent clinics, and independent clinic services provided by certain regulated healthcare professionals were brought into the registration regime, which extended registration to a body of activity that had previously sat outside it.

The practical effect is straightforward. Where a service in Scotland is provided by a regulated healthcare professional in an independent clinic setting, there is a real prospect that registration is required, and therefore a real prospect that a public entry and an inspection report exist for you to read. That is a better position for a patient than the equivalent English one for the same treatment.

What has not changed is the general principle from the scope article. Registration attaches to defined services, and the definitions matter. A person who is not a regulated healthcare professional providing a service that falls outside the definitions may not be caught.

Register check 01Whether an independent clinic in Scotland is registered
Open
Healthcare Improvement Scotland, independent healthcare services
healthcareimprovementscotland.org
Type in
The registered provider name from Companies House first, then the clinic trading name, then the town or street address. Follow the site's route to independent healthcare service registration and inspection reports.
A good result looks like
A registered service at the address where you will be treated, with the service type stated, a current registration status, and any inspection reports available to read in full.
An ambiguous result looks like
A service registered at a different address run by the same provider. A registration whose stated service type does not obviously include your treatment. Nothing found, in which case ask the provider directly whether registration is required for the service you are buying.
What it does not prove
That your specific treatment is covered by the registration, that the person treating you was individually assessed, or that a prescription was lawfully written for you.
Note
The Scottish scope differs from the English one. Do not reason from a CQC answer to a Scottish conclusion, or the reverse.

Reading a Scottish entry

Look for the same categories you would look for anywhere: which service is registered, at which address, under which provider, with what status, and with what published inspection history.

Where inspection reports exist, read them in full. Scottish inspection reports typically describe what was examined and set out requirements and recommendations. A requirement is something the service must do. A recommendation is advisory. Both are informative, and a service that has responded properly to a requirement may be in a better position than one never looked at.

Where Scotland and England differ, in patient terms

Three practical differences are worth carrying.

Coverage. A cosmetic service delivered by a regulated healthcare professional in Scotland is more likely to sit inside a registration scheme than the same service delivered in England. Do not assume the English answer applies.

Vocabulary. The service categories and the language of inspection reports differ from the English ones. Read the Scottish definitions rather than translating from CQC vocabulary.

Licensing. The Health and Care Act 2022 licensing power for non surgical cosmetic procedures is an England provision. Do not expect it to produce a Scottish licence, whatever its commencement status. That is covered in the licensing position.

Same treatment, two nations, different questions
QuestionEnglandScotland
Which body registers premisesCare Quality CommissionHealthcare Improvement Scotland
What triggers registrationCarrying on a defined regulated activityProviding an independent clinic service, including by certain regulated healthcare professionals
Laser for cosmetic purposesOutside CQC since 2010, local authority licensing variesCheck the Scottish scheme and the local authority for the address
Non surgical licensing powerSection 180 of the Health and Care Act 2022, an England powerNot applicable
Under 18s toxin and filler offenceBotulinum Toxin and Cosmetic Fillers (Children) Act 2021, EnglandCheck the position for Scotland specifically
Small claims routeCounty courtSimple procedure in the sheriff court

A framework written by this publication to organise the procedure. It is not a measurement, a guideline or a regulator's classification.

The parts that do not change at the border

Several things are United Kingdom wide and are unaffected by which nation you are in.

  • Professional registers. The GMC, NMC, GDC and HCPC registers are UK wide, and the GPhC covers Great Britain. Check them the same way wherever you are.
  • Medicines law. The Human Medicines Regulations 2012 apply across the UK. Botulinum toxin is a prescription only medicine in Scotland exactly as it is in England, and the same questions about who prescribed and who assessed you apply.
  • Consumer law. The Consumer Rights Act 2015 and the Consumer Contracts Regulations 2013 apply in Scotland, though the courts and procedures for enforcing them differ. Small claims are handled through the simple procedure in the sheriff court rather than the English county court process.
  • Advertising rules. The CAP Code and the Advertising Standards Authority operate across the UK.

One difference worth naming: the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 is an England provision. Do not assume it applies in Scotland. The position on under 18s is set out in the under 18s article, and if you are anywhere other than England you should check the position for that nation specifically.

Complaints in Scotland

Where a service is registered with Healthcare Improvement Scotland, that body can receive concerns about it, and it publishes how to raise them. Where the practitioner is a statutory registrant, the UK professional regulator remains the route for concerns about that individual, wherever in the UK they practised.

For money and contract matters, consumer routes apply, with the Scottish court procedures noted above. Trading standards services operate in Scotland through local authorities, and Advice Direct Scotland provides consumer advice. Keep the same file you would keep anywhere: dated register screenshots, the quotation, the consent documents, the product and batch details and the aftercare sheet.

The Scottish version of the written questions

  1. Are you registered with Healthcare Improvement Scotland for the service I am buying, and under what name.
  2. If not, on what basis does the service fall outside registration.
  3. Who is the regulated healthcare professional responsible for my treatment, and what is their registration number.
  4. If a prescription only medicine is involved, who prescribes it and when will they assess me.
  5. Does the local authority for this address operate any licence that applies to this treatment.

These are short questions with short answers. A provider that answers them clearly has made your file for you. A provider that will not answer the first has answered it anyway.

Common questions

Is a cosmetic clinic in Scotland regulated differently from one in England?

Yes. Scotland brought independent clinic services provided by certain regulated healthcare professionals into registration with Healthcare Improvement Scotland. The scope is not the same as the English regulated activities, so a service unregistered in England may require registration in Scotland.

How do I check whether a Scottish clinic is registered?

Search the Healthcare Improvement Scotland website for the service, using the registered provider name, the trading name and the address. Read which service type is registered and any published inspection report.

Does the English licensing power in the Health and Care Act 2022 apply in Scotland?

No. That licensing power is an England provision. Whatever its commencement position, it does not create a Scottish licence.

Does the ban on toxin and fillers for under 18s apply in Scotland?

The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 is an England provision. Check the position for the nation you are in rather than assuming a UK wide rule.

Do UK professional registers work the same way in Scotland?

Yes. The GMC, NMC, GDC and HCPC registers are UK wide and the GPhC covers Great Britain. Medicines law and advertising rules are also UK wide.

Sources and registers

Links to regulators, registers and published law. They are cited because they are public and checkable, not as endorsement of this publication. Open each one and read it yourself.

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