An ad for facial injections on a discount website, seen on www.groupon.co.uk on 2 January 2012, was headed "£49 for a Choice of One Facial Injection Treatment at Aesthetic Angels (Up to 59% Off)". Further text stated "Alongside jumping on a pogo stick under bird nests, facial injections are one of the best ways to target crows' feet. Kill two birds with one stone with today's Groupon: £49 for a choice of one facial injection treatment at Aesthetic Angels ... With a decade in the industry behind them, the cosmetically trained, registered nurses at Aesthetic Angels offer a trove of different ways to smooth things over. At the salon in central Newcastle, customers can decide on a choice of one facial injection treatment to best suit their needs. Customers can also choose to have the treatment in one of a range of areas, including the forehead, frown lines, mouth, or crows' feet".
Terms and conditions stated "Limit 1 per person. May buy multiple as gifts. Booking required. 24 hour cancellation policy. Must be 18 or over with valid ID. Consultation included. Full refund provided if client is deemed unsuitable".
The complainant challenged whether it was irresponsible to offer facial injections, a medical procedure provided by a registered nurse, as part of a time-limited offer.
MyCityDeal Ltd t/a Groupon (Groupon) did not believe the ad was irresponsible. They emphasised that the facial injections would be carried out by qualified health professionals. They said the only part of the offer that was time limited was the purchase of the voucher, not the provision of the service. They said the decision to receive the service could be made at any point within the validity of the voucher, which in this case was three months. They said a refund was attainable at any point prior to redemption for facial injection treatments. They said they had recently introduced a new policy whereby all deals offering facial injections ran for a minimum of 72 hours, to reduce any pressure on consumers' decisions to purchase, and confirmed this offer ran for this period.
The ASA noted the procedures offered would be carried out by a registered nurse. We considered it was important that consumers were not pressured into a decision to purchase cosmetic procedures, such as facial injections, that would have long lasting physical effects. We noted the complainant believed it was not appropriate to offer facial injections as part of a time-limited offer. However, we considered that 72 hours was sufficient time for consumers to make a decision to purchase the voucher, and also noted that a refund was attainable at any point prior to the voucher being redeemed in the case of a consumer changing his or her mind. We also considered that most consumers would be aware of the availability of facial injections for the purposes described in the ad, and did not consider that the ad placed undue pressure on consumers. We therefore concluded the ad was not irresponsible.
We investigated the ad under CAP Code (Edition 12) rules 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Social responsibility) and 12.3 12.3 Marketers offering individual treatments, especially those that are physically invasive, may be asked by the media and the ASA to provide full details together with information about those who supervise and administer them. Practitioners must have relevant and recognised qualifications. Marketers should encourage consumers to take independent medical advice before committing themselves to significant treatments, including those that are physically invasive. (Medicines, medical devices, health-related products and beauty products) but did not find it in breach.
No further action necessary.