PFD report

LEAH LOUISE CAMBRIDGE · Prevention of Future Deaths report

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Issued 29 Nov 2019•West Yorkshire (East)

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
3

Raised in this report

Recipients
3

Named on the report

Responses found
2

Of 3 recipients

Stated actions
10

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised3

  1. Lack of prescribed regulatory guidance on BBL surgical techniques
  2. Lack of regulatory intervention and control of BBL procedures in the UK
  3. Failure to obtain informed consent for BBL procedures
    Part of recurring concern: Inadequate informed-consent processes for medical treatment
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.2

  1. Action

    Update existing surgical fat transfer guidance to reference Brazilian Butt Lift procedures, informed by stakeholder liaison and current clinical information.

    Stated by Department of Health and Social CareStated in progressThe respondent said that this action was in progress when they made their response on 29 December 2019.
  2. Action

    Publish revised consent guidance with tailored specialty materials emphasising time for patients to consider treatment information.

    Stated by General Medical CouncilStated plannedThe respondent said that this action was planned when they made their response on 29 December 2019.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.1

  1. Position

    Clinical guidance on surgical techniques is the role of other bodies, such as the Royal Colleges of Surgeons.

    Stated by General Medical CouncilOutside remitThe respondent said that this matter was outside its role or authority.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of prescribed regulatory guidance on BBL surgical techniques

Wider context from the report

“(3) If BBL procedures continue to be permitted in the UK, I consider there is a need for the regulatory authorities to consider prescribing guidance on the surgical techniques to be employed and the information to be provided before a person incurs expense. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of regulatory intervention and control of BBL procedures in the UK

Wider context from the report

“(1) Notwithstanding (a) the death of Ms Cambridge on 27.8.18; and (b) concerns expressed in relation to the risks involved in BBL procedures by a task force established under the auspices of the Aesthetic Surgery Education and Research Foundation (ASERF); and (c) a voluntary moratorium declared by the British Association of Aesthetic and Plastic Surgeons (‘BAAPS’) The Inquest heard evidence that some plastic surgeons in the UK continue to carry out BBL procedures. Furthermore, that Elite Aftercare continue to facilitate other clients to travel to Turkey for the purpose of BBL procedures to be undertaken by surgeons such as ████████. I am concerned at the lack of intervention and control of BBL procedures by the regulatory authorities in the UK. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to obtain informed consent for BBL procedures

Wider context from the report

“(2) In order to make an informed decision as to the wisdom of undertaking effective cosmetic surgical procedures such as BBL, it is important that the person involved receive adequate information regarding the mortality and morbidity risks involved. In order to read and absorb such information it needs to be provided prior to any commitment being made or expense incurred. The Inquest into the death of Ms Cambridge heard that she was provided with a substantial quantity of material (some of which was written in Turkish) on the morning of the surgery and required to sign each page. The Inquest found she had insufficient time to digest this complex material, even if she was in a frame of mind to try, shortly before being taken to theatre. My concern is that informed consent is not obtained. ”

Is this part of a recurring concern?

Yes — Inadequate informed-consent processes for medical treatment.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Update existing surgical fat transfer guidance to reference Brazilian Butt Lift procedures, informed by stakeholder liaison and current clinical information.

Verbatim wording from the response

“The Department will be updating existing guidance about surgical fat transfer procedures, which the Brazilian ButtLift falls under, to reference the procedure. The Department is liaising with stakeholders to check the latest clinical information and expects the updates to guidance to be made by March 2020.”

Source location

2019-0408-Response-from-The-Department-of-Health-and-Social-Care
Page 2 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Publish revised consent guidance with tailored specialty materials emphasising time for patients to consider treatment information.

Verbatim wording from the response

“We will be publishing a revised version of the guidance later this year which will place even greater emphasis on giving adequate time for a patient to digest the information and reach a decision about treatment. It will be supported by tailored materials for specialties where we know there are issues with applying the guidance in practice.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 3 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Clinical guidance on surgical techniques is the role of other bodies, such as the Royal Colleges of Surgeons.

Verbatim wording from the response

“We do not provide clinical guidance on surgical techniques, that is the role of other bodies such as the Royal Colleges of Surgeons.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 3 · response
Published 29 December 2019

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.8

  1. 1

    Review whether to publish further information on Brazilian Butt Lift procedures after the Inter-Society Task Force reports its findings.

    Stated by Department of Health and Social CareStated plannedThe respondent said that this action was planned when they made their response on 29 December 2019.
  2. 2

    Hold a review point after early-adopter credentials complete approval, including further engagement and evaluation before accepting additional submissions.

    Stated by General Medical CouncilStated plannedThe respondent said that this action was planned when they made their response on 29 December 2019.
  3. 3

    Continue discussions with organisations interested in proposing GMC-regulated credentials.

    Stated by General Medical CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 December 2019.
  4. 4

    Operate task-and-finish groups involving professional, government and training stakeholders to review initial credentials and inform processes.

    Stated by General Medical CouncilStated completedThe respondent said that this action was complete when they made their response on 29 December 2019.
  5. 5

    Work with the Royal College of Surgeons (England) to prepare and submit a cosmetic surgery credential proposal for approval.

    Stated by General Medical CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 December 2019.
  6. 6

    Consider how to identify and prioritise areas for future GMC-regulated credentials.

    Stated by General Medical CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 December 2019.
  7. 7

    Continue the phased introduction and approval testing of GMC-regulated credentials in priority areas.

    Stated by General Medical CouncilStated in progressThe respondent said that this action was in progress when they made their response on 29 December 2019.
  8. 8

    Publish a patient leaflet explaining considerations when seeking cosmetic treatment abroad.

    Stated by General Medical CouncilStated completedThe respondent said that this action was complete when they made their response on 29 December 2019.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.5

  1. 1

    Restricting or imposing conditions on companies facilitating cosmetic surgery holidays abroad is outside the Department’s remit.

    Stated by Department of Health and Social CareOutside remitThe respondent said that this matter was outside its role or authority.
  2. 2

    Legislative change to prohibit the procedure is outside the authority to create legislation or outlaw specific treatments.

    Stated by General Medical CouncilOutside remitThe respondent said that this matter was outside its role or authority.
  3. 3

    Concerns about named doctors in Turkey who are not GMC-registered should be referred to Turkey’s relevant medical regulator.

    Stated by General Medical CouncilRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.
  4. 4

    GMC-regulated credentials cannot be mandatory because there is no legal authority to mandate postgraduate training or credentials.

    Stated by General Medical CouncilUnable to actThe respondent said that a constraint prevented them from taking the relevant action.
  5. 5

    Concerns about UK clinics referring patients overseas should be considered by the relevant systems regulators and improvement bodies.

    Stated by General Medical CouncilRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Review whether to publish further information on Brazilian Butt Lift procedures after the Inter-Society Task Force reports its findings.

Verbatim wording from the response

“Once the Inter-Society Gluteal Fat Grafting Task Force into the Brazilian ButtLift procedure has reported its findings, the Department will review whether further information should be published on the procedure.”

Source location

2019-0408-Response-from-The-Department-of-Health-and-Social-Care
Page 2 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Hold a review point after early-adopter credentials complete approval, including further engagement and evaluation before accepting additional submissions.

Verbatim wording from the response

“We have set up task and finish groups to allow stakeholders from the profession, government and training organisations to help review the first credentials and input into processes. We will also hold a review point once the early adopter credentials have been through the approval processes, allowing further engagement and evaluation, before we proceed with accepting more submissions for future credentials.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue discussions with organisations interested in proposing GMC-regulated credentials.

Verbatim wording from the response

“Alongside this work, we are considering how to identify and prioritise areas for future GMC-regulated credentials. In the meantime, we are continuing conversations with organisations interested in putting forward a proposal for a credential.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Operate task-and-finish groups involving professional, government and training stakeholders to review initial credentials and inform processes.

Verbatim wording from the response

“We have set up task and finish groups to allow stakeholders from the profession, government and training organisations to help review the first credentials and input into processes. We will also hold a review point once the early adopter credentials have been through the approval processes, allowing further engagement and evaluation, before we proceed with accepting more submissions for future credentials.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with the Royal College of Surgeons (England) to prepare and submit a cosmetic surgery credential proposal for approval.

Verbatim wording from the response

“We began a phased introduction of GMC-regulated credentials late last year, starting with five early adopters in priority areas. These are currently going through our approval processes, to allow us to test and learn if any changes are needed to the credentialing framework or to our processes. One of the early adopters we are working with is a proposal from the Royal College of Surgeons (England) on cosmetic surgery. We have been working with the College as they prepare their submission, and we expect it to enter our approval processes later in 2020.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider how to identify and prioritise areas for future GMC-regulated credentials.

Verbatim wording from the response

“Alongside this work, we are considering how to identify and prioritise areas for future GMC-regulated credentials. In the meantime, we are continuing conversations with organisations interested in putting forward a proposal for a credential.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue the phased introduction and approval testing of GMC-regulated credentials in priority areas.

Verbatim wording from the response

“We began a phased introduction of GMC-regulated credentials late last year, starting with five early adopters in priority areas. These are currently going through our approval processes, to allow us to test and learn if any changes are needed to the credentialing framework or to our processes. One of the early adopters we are working with is a proposal from the Royal College of Surgeons (England) on cosmetic surgery. We have been working with the College as they prepare their submission, and we expect it to enter our approval processes later in 2020.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Publish a patient leaflet explaining considerations when seeking cosmetic treatment abroad.

Verbatim wording from the response

“Finally, we also publish a leaflet for patients to raise awareness of the things to consider when seeking cosmetic treatment abroad. We urge those who seek care abroad to consider whether the standard will match that which we expect of doctors in the UK.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 3 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Restricting or imposing conditions on companies facilitating cosmetic surgery holidays abroad is outside the Department’s remit.

Verbatim wording from the response

“Finally, it is not within the Department of Health and Social Care’s remit to restrict or impose conditions on companies that facilitate cosmetic surgery holidays abroad. However, we strongly recommend that people do not travel abroad for cosmetic surgery as the clinics and surgeons may not be subject to the same levels of regulation, safety and training as in the UK. The standards set by the GMC and the RCS represent good practice and where someone is considering a cosmetic procedure abroad, we urge them to carefully consider the standards of care that apply in the country where the procedure will be carried out.”

Source location

2019-0408-Response-from-The-Department-of-Health-and-Social-Care
Page 2 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Legislative change to prohibit the procedure is outside the authority to create legislation or outlaw specific treatments.

Verbatim wording from the response

“Whilst I understand you are advocating for legislative change to prohibit this procedure, we do not have powers to create legislation or outlaw specific treatments. I know you have written to the Secretary of State for Health and Social Care about this.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 2 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Concerns about named doctors in Turkey who are not GMC-registered should be referred to Turkey’s relevant medical regulator.

Verbatim wording from the response

“with the GMC, working anywhere in the world. If you have any concerns about the fitness to practise of individual, named doctors working in Turkey who are not registered with the GMC you should notify the relevant medical regulator as set out below.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 5 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

GMC-regulated credentials cannot be mandatory because there is no legal authority to mandate postgraduate training or credentials.

Verbatim wording from the response

“While GMC-regulated credentials may help clarify the capabilities of some doctors performing cosmetic surgical interventions, there are wider regulatory and social changes necessary to protect people from cosmetic surgery risks such as better regulation of sites, devices and more explicit expectations about communicating these risks with potential clients. GMC-regulated credentials will not be mandatory for doctors working in a specific area of practice, as the GMC does not have the legal authority to make any postgraduate training mandatory, including credentials. This is similar to working in a specialty, where it is not a requirement for a doctor to have specialist registration in an area of practice, to work in that area.”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 4 · response
Published 29 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Concerns about UK clinics referring patients overseas should be considered by the relevant systems regulators and improvement bodies.

Verbatim wording from the response

“You express understandable concern about organisations based in the UK referring patients overseas for cosmetic procedures. Concerns about the activity of independent clinics based in the UK arising from this case should be referred to the systems regulators and improvement bodies to consider. These are different in each of the jurisdictions of the UK: the Care Quality Commission (in England), Healthcare Improvement Scotland, Healthcare Inspectorate Wales and the Regulatory Quality and Improvement Authority (in Northern Ireland).”

Source location

2019-0408-Response-from-the-General-Medical-Council-1
Page 2 · response
Published 29 December 2019

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026