Summary of Council decision:Two issues were investigated, both of which were Upheld.
The Facebook page for Aesthetics Lounge Academy, a beauty course provider, seen on 21 February 2019, featured a post which stated "Do you want to become a Dermal Filler or Anti Wrinkle (Botox) Practitioner? Do you want a qualification in NVQ Level 3 Diploma in Beauty Therapy? Our VTCT NVQ Level 3 in Beauty Therapy works as a bridging course to aesthetics" and "Our modules are specifically selected to allow our students to progress directly onto our aesthetics courses such as Dermal Fillers or Anti Wrinkles (Botox)".
Text on the ‘About’ page stated "The Aesthetics Lounge Academy works closely alongside the Aesthetics Lounge and offers a wide range of accredited aesthetic training courses to all suitably qualified individuals".
The Joint Council for Cosmetic Practitioners (JCCP), who believed the training course did not conform to their own standards, challenged whether the following claims were misleading and could be substantiated:
1. "Our VTCT NVQ Level 3 in Beauty Therapy works as a bridging course to aesthetics"; and2. "The Aesthetics Lounge Academy … offers a wide range of accredited aesthetic training courses to all suitably qualified individuals".
1. Aesthetics Lounge Academy Birmingham Ltd (Aesthetics Lounge Academy) said their intention was to explain that the NVQ Level 3 course was a starting point into aesthetics and did not necessarily provide a straightforward route to it. They said they would change the claim to make it clear it was a starting point as opposed to a bridging course.2. Aesthetics Lounge Academy said their courses were accredited by the CPD Certification Service, which offered accreditation across the industry.
1. & 2. Upheld
The ASA noted that the post contained the words “PATHWAY TO AESTHETICS” next to an image of a woman smiling, with her hands on her cheeks, in addition to the words “Do you want to become a Dermal Filler or Anti Wrinkle (Botox) Practitioner?” which appeared at the top of the post. Further claims included “Our VTCT NVQ Level 3 in Beauty Therapy works as a bridging course to aesthetics” and “The Aesthetics Lounge Academy … offers a wide range of accredited aesthetic training courses to all suitably qualified individuals”.
We considered that prospective students seeking a career in beauty therapy would understand from the post that completing the VTCT NVQ Level 3 would enable them to move directly onto a further course that gave them the knowledge and skills needed to begin administering dermal filler and Botox professionally. As such, we considered that the ad should have provided them with the information they needed to make an informed decision as to whether or not to enquire further about enrolling on the course.
We noted that on their web page entitled “Choosing who will do your cosmetic procedure”, the NHS advised patients they could check if medical professionals were listed on relevant statutory or voluntary registers, including the JCCP’s register, which informed patients that practitioners met set standards of training, insurance and skill. The page also gave advice specifically to patients seeking dermal filler, advising them to avoid practitioners who had only completed a short training course in their chosen procedure. It noted that complications of treatment could be serious, including infection, nerve damage and blindness.
We considered that prospective students might have been unfamiliar with the advice given by the NHS, but that such information was likely to impact on prospective patients’ choice of practitioner. In that context, we considered that ads for training courses that were intended to provide students with qualifications relevant to the administration of beauty treatments such as dermal filler should have provided information on: the requirements for acceptance onto the course; the nature and duration of the training; the qualification that would be attained; and whether the qualification met the standards necessary for admittance onto a relevant professional register.
We considered that information to be important because it gave students an indication of the likelihood of the course giving them the knowledge and skills required to safely carry out the procedures independently. We had not seen information that demonstrated that graduates of either the advertised course or the further aesthetics courses were eligible for registration on a relevant professional register, and no information had been provided on the course length. While the post referred to a VTCT NVQ Level 3 in Beauty Therapy, we noted the text “The course content will involve theory work, practical work, practical assessments, the development of a portfolio and end of course exams”, which we considered was ambiguous and did not sufficiently inform students of what the course covered.
In addition, no information on the minimum standard for entry onto the course was provided. Consequently, it was not clear from the information provided how students would obtain the knowledge or practical experience required to move onto a further course that gave them the skills and knowledge needed to begin safely administering the procedures, or to deal with complications if things went wrong.
We welcomed Aesthetics Lounge Academy’s willingness to make changes to the ad. However, we considered the proposed amendments were not sufficient to prevent the ad from misleading. Because the ad omitted information on the duration of training, requirement for acceptance and whether the qualification provided access onto a relevant professional register, we concluded the claims “Our VTCT NVQ Level 3 in Beauty Therapy works as a bridging course to aesthetics" and “The Aesthetics Lounge Academy … offers a wide range of accredited aesthetic training courses to all suitably qualified individuals" were misleading.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising).
The ad must not appear again in the form complained of. We told Aesthetics Lounge Academy Birmingham Ltd to ensure their future advertising did not omit material information, such as the requirements for acceptance onto the course, the nature and duration of the training and whether the qualifications met the standards necessary for admittance onto a relevant professional register.