ASA Advertising Guidance
Whilst the BAHRS does not consider hair transplant surgery to be a cosmetic surgery procedure, the principles covered by the ASA Guidance Note apply fully to Hair Restoration Surgery.
A summary can be found here but some of the subjects covered by the ASA Guidance Note are:
1. 'qualified’ - surgeons looking to claim they are ‘qualified’, ‘highly qualified’ or 'fully qualified' should only do so if they are on the Specialist Register of the General Medical Council (GMC) in respect of a relevant surgical specialty or were practicing cosmetic surgery independently before 1 April 2002, and they should hold a Certificate of Completion of Specialist Training (CCST) in plastic surgery or an equivalent qualification. Surgeons wanting to claim they are ‘qualified’, 'highly qualified' or ‘fully qualified’ in a particular area of cosmetic surgery, e.g. ophthalmological procedures, should hold a CCST or equivalent in the relevant surgical speciality (Rule 12.3);
2. ‘experienced’ – the ASA normally expects marketers claiming surgeons are ‘experienced’ or ‘highly experienced’ to be able to show surgeons have practiced their surgical speciality for at least 6 years, the minimum NHS requirement for completion of specialist training;
3. ‘specialist’ – ‘specialist’ or ‘specialising in’ is understood to denote a surgeon whose main area of expertise is in a particular discipline, for example, cosmetic or plastic surgery;
4. ‘leading’ – marketers looking to prove claims such as ‘leading surgeons’ or 'foremost surgeons' would need to show that the surgeons’ achievements and experience put them at or near the top of their speciality;
5. ‘consultants’ – ‘consultants’ should have held an NHS Consultant post (not a locum position) or the equivalent in the speciality to which the marketing communication refers and
6. clinics – marketers should hold evidence to demonstrate the pre-eminence of their clinic (not just a few of their surgeons) before claiming they are a ‘leading’ clinic and should avoid implying that all their surgeons are of a particular standard if they are not. Clinics should not link themselves with renowned locations such as Harley Street unless they carry out consultations or surgery there.
Marketers must also ensure that they hold robust clinical evidence for the efficacy of their product or service. In 2015, the ASA upheld a complaint about a hair transplant company because they could not prove that “Before and After” imagery they used represented what could generally be achieved by their patients (The Hospital Medical Group Ltd, 19 August 2015).