Two Facebook posts for The Secret Diamond Academy, an aesthetics training academy, posted by the account of Rebecca Barton, the academy's director:
a. The first ad, posted on 7 August 2022, included a photo of a person’s leg at different stages of treatment for thread veins. Text stating “THREAD VEIN REMOVAL COURSE” was overlaid across the image, and text above it stated “Fully Accredited Course”, along with a logo for the CPD accreditation group. Accompanying text stated “Sclerotherapy training … Best selling course … Amazing results … Vein free … fully accredited … blended learning available qualification dependant [sic] … DM or call to book.”
b. The second ad, posted on 10 October 2022, included two photos of a person’s leg as a “before and after” comparison, following treatment for thread veins. Accompanying text stated Sclerotherapy training course available [mortarboard emoji] … #thesecretdiamondacademy … Book your training course now!!”
The ASA challenged whether ads (a) and (b) were misleading because they offered training courses for sclerotherapy, without making clear the nature, requirements, qualifications and possible professional registration details of the course.
The Secret Diamond Academy said that consumers could only book a place on their training courses by telephone, and that when people enquired about courses, they were made aware of all qualifications and requirements necessary in order to be enrolled on a training course. They said they could also answer questions about their training courses on social media if they were contacted that way.
The ASA noted that ad (a) stated “Fully Accredited Course”, “Sclerotherapy training” and “Best selling course”. Further claims included “fully accredited” and “blended learning available qualification dependant [sic]”. We noted that ad (b) stated “Sclerotherapy training course available” and “Book your training course now!!”, as well as a description of what sclerotherapy treatments entailed.
We considered that prospective students seeking a qualification which would enable them to perform sclerotherapy treatments would understand from the ads that completing the Secret Diamond Academy’s sclerotherapy training course would give them the knowledge and skills needed to begin administering such treatments professionally.
As such, we considered that the ads 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 “Choosing who will do your cosmetic procedure”, the NHS advised patients that they could check if professionals offering cosmetic procedures were listed on a voluntary register accredited by the Professional Standards Authority, including the Joint Council of Cosmetic Practitioners, which informed patients that practitioners met set standards of training, insurance and skill.
The NHS page advised patients considering undergoing cosmetic treatments which required a prescription to ensure that the person giving them the injections was trained and safe to do so, and to make sure they knew what training and experience they had. Further advice recommended that patients avoided practitioners who had only completed a short training course, due to potential complications and risk.
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 treatments such as sclerotherapy should have provided information on: the minimum requirements for acceptance onto the course; the qualification that would be attained; the nature and duration of the training; and whether the qualification met the standards necessary for admittance onto a relevant professional register. We considered that information to be material 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 noted that neither of the ads stated what the minimum requirements for acceptance onto the course were, what qualification would be attained upon completion of the course, the nature and duration of the training, or whether the qualification met the standards necessary for admittance onto a relevant professional register. We acknowledged that ad (a) stated “fully accredited” and “Fully Accredited Course”, along with a logo for the CPD accreditation group, who we understood were a nationally recognised accreditation and certification body. It was not clear, however, what that accreditation entailed, or how it related specifically to the training of people to carry out sclerotherapy treatments.
Because the ads omitted the material information listed above, we concluded they were both likely to mislead.
The ads breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising).
The ads must not appear again in the form complained of. We told The Secret Diamond Academy 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, the qualification that would be attained and whether the qualification met the standards necessary for admittance onto a relevant professional register.