I have recently been asked to give an expert opinion on a criminal case around safeguarding the public undergoing treatments within a beauty establishment. This was a timely request as it fell just as the Department of Health and Social Care (DHSC) launched its public consultation on the Licensing of non-surgical procedures in England (DHSC 2023). I read the consultation document and government webpage with interest and was surprised to see the word safeguarding was not anywhere within the content of the document.
Just to add some background, the licensing proposal was added into the Health and Social Care Act 2022 as an amendment and gives the Secretary of State certain powers to introduce licensing for the purposes of ‘reducing the risk of harm’ to the health or safety of members of the public, when undergoing cosmetic interventions.
One proven way of reducing harm to the public is by the use of the Disclosure and Barring Service (DBS), previously known as the Criminal Records Bureau (CRB). This helps employers make safer recruitment decisions each year by processing and monitoring checks for staff. This in turn plays an important role by protecting vulnerable adults, young adults and children from those who are deemed unsuitable gaining access to them through their roles.
As registered nurses we are mandated by the NMC Code to preserve safety. Those of us who have current NHS roles or work within a CQC-registered establishment are mandated to have in place a DBS check monitored and audited regularly. When working with children and vulnerable adults this must be an enhanced DBS check.
The DBS check is not listed as a mandatory requirement for nurses to revalidate with the NMC, but in my opinion it should be. Neither is a DBS check a mandatory requirement for cosmetic nurses practising aesthetics. This is despite Keogh referring to those who seek out these cosmetic treatments as being vulnerable (Keogh 2013).
The Professional Cosmetic/Aesthetic Nursing organisations could do more to protect the public and encourage or even mandate that their members have in place a DBS check and that their members be encouraged to join the DBS online service.
If DBS checks for doctors and nurses within the private aesthetic sector are at best scanty, then they are almost non-existent within the lay groups who provide 14-year-old children with spray tans and promote pamper parties for children from the age of six and where are any safeguarding checks for vulnerable dementia patients undergoing a manicure in their own home? Beauticians expose and handle intimate areas when performing procedures such as waxing and peels. Those undergoing intimate bikini and buttock area laser hair removal treatments are often visually impaired due to the eye protection they must wear, this makes them vulnerable to being covertly photographed. The recent criminal case has proved predators will always find their way to the vulnerable – be that a child, a young adult or a vulnerable adult.
Whilst I support the licensing initiative, it appears to me that the whole landscape on safeguarding the public within the cosmetic sector and beauty industry must now be urgently addressed. There is a safeguarding gap here in plain sight and no, we cannot wait until 2027 for licensing to mandate DBS checks within the beauty and cosmetic industry. We need these checks, and we need them now.