Legal Responsibilities for Small Beauty and Aesthetics Businesses in Preventing Fake Reviews

Publishing client feedback has become an essential part of business strategy for beauty and aesthetics clinics, shaping public perception and influencing consumer decisions.

Online reviews—whether on your own website, social media, or third-party platforms—can be a powerful tool for attracting new clients and building credibility.

However, with this power comes legal responsibility. The proliferation of fake reviews poses significant risks, both to your reputation and to your compliance with UK law.

This article will guide small beauty and aesthetics businesses through their obligations and potential liabilities surrounding client feedback. We will examine relevant legislation, enforcement trends, best practices, and practical steps to help you navigate this complex landscape—and protect your business from costly legal consequences.

Understanding the Legal Landscape: What Are Fake Reviews?

Fake reviews are any client feedback that is fabricated, misleading, or does not reflect a genuine customer experience. This can include:

Fabricating reviews for your own business
Commissioning others to write positive feedback without experiencing your services
Negative reviews posted by competitors or third parties to damage your reputation
Editing or selectively publishing reviews to create a false impression

The Competition and Markets Authority (CMA) in the UK has taken a strong stance against misleading online endorsements. Posting, soliciting, or otherwise facilitating fake reviews not only undermines consumer trust but can also constitute a breach of consumer protection laws.

Legal Responsibilities Under UK Law

Consumer Protection from Unfair Trading Regulations 2008 (CPRs)

This legislation prohibits businesses from engaging in unfair commercial practices, including misleading actions and omissions. Specifically:

Misleading actions: Providing false information or creating a misleading impression about the nature or quality of goods or services.
Misleading omissions: Failing to provide material information that consumers need to make informed decisions.

Publishing fake client feedback falls within these categories, as it can deceive consumers and distort purchasing choices. Non-compliance can lead to enforcement by authorities, criminal prosecution, and substantial fines.

The Role of the Competition and Markets Authority (CMA)

The CMA monitors online reviews and takes action against businesses that manipulate or fabricate feedback. Recent enforcement actions have targeted companies across various sectors, including beauty and aesthetics, for practices such as:

Paying for positive reviews
Suppressing negative feedback
Incentivising clients to post favourable reviews without full disclosure

If the CMA determines that your clinic is involved in misleading review practices, it can issue undertakings, seek court orders, and pursue criminal charges. In addition, adverse publicity can damage your reputation irreparably.

Advertising Standards and ASA Guidance

The Advertising Standards Authority (ASA) is responsible for ensuring that all marketing communications are legal, decent, honest, and truthful. If client feedback is published as part of your advertising—or used in promotional material—it must comply with the CAP Code (UK Code of Non-broadcast Advertising and Direct & Promotional Marketing).

Testimonials must be genuine and accurately reflect the reviewer’s experience.
Any incentives provided for reviews must be disclosed clearly.
Businesses must not cherry-pick or edit reviews to mislead consumers.

Failure to comply with ASA guidance can result in investigations, sanctions, and removal of advertising campaigns.

Data Protection and Privacy Concerns

When publishing client feedback, small clinics must also comply with data protection laws. The General Data Protection Regulation (GDPR) requires that any information identifying individuals—such as names or photographs—be handled lawfully, fairly, and transparently. Written consent should be obtained before sharing personal data in testimonials.

Risks and Penalties for Non-Compliance

Civil and Criminal Proceedings

Breaching consumer protection regulations exposes your business to:

Official investigations and enforcement action by the CMA and Trading Standards
Fines, which can reach unlimited amounts depending on the severity of the breach
Criminal prosecution for fraudulent activities
Damages claims from consumers or competitors

Reputational Damage

Beyond legal penalties, the revelation of fake reviews can cause significant harm to your clinic’s reputation. Trust is a cornerstone of the beauty and aesthetics industry; once lost, it is exceptionally difficult to regain. Negative publicity can result in loss of clients, reduced revenue, and challenges in recruiting skilled staff.

Contractual Consequences

If you use third-party platforms (e.g., Google, Trustpilot, Facebook) to host client feedback, violating their terms of service by posting or soliciting fake reviews can result in removal of your business listing, suspension from the platform, and loss of associated benefits.

Best Practices for Compliance and Authentic Feedback

Implement Robust Review Policies

Develop and enforce clear policies for collecting, publishing, and moderating client feedback. Ensure every review published on your website or marketing materials is genuine and accurately attributed. Consider:

Using verified purchase systems to confirm client identity
Monitoring review platforms for suspicious or fake postings
Training staff to recognise and report non-compliant practices

Encourage Honest, Unbiased Feedback

Invite clients to share their experiences, but avoid offering rewards or incentives that could influence the content of their reviews. If you do provide incentives, disclose this openly in accordance with ASA and CMA guidance.

Respond Transparently to Negative Reviews

Rather than suppressing negative feedback, engage constructively with clients who raise concerns. Demonstrating a commitment to resolving issues fosters trust and can turn criticism into an opportunity for improvement.

Obtain Proper Consent for Testimonials

Always secure written consent before publishing any personal data (names, images, treatment details) in client feedback. Ensure your privacy notices clearly explain how this information will be used and stored.

Monitor Third-Party Platforms

Regularly audit your presence on popular review sites. Report suspected fake reviews to platform administrators and provide evidence if needed. Avoid retaliating with fake negative reviews against competitors, as this behaviour is equally unlawful.

Enforcement Trends and Future Developments

The UK government and industry regulators are increasingly focused on promoting transparency and eliminating fake reviews. Enforcement activity is expected to rise, especially in sectors where consumer safety and well-being are paramount, such as beauty and aesthetics. Remaining proactive and diligent in your review management is essential for safeguarding your business.

Protect Your Clinic and Build Trust

Small beauty and aesthetics businesses must take the legal responsibilities around client feedback seriously. Preventing fake reviews is not only a matter of compliance but also a fundamental aspect of building long-term trust and success in the industry. By implementing robust policies, staying informed about regulatory changes, and prioritising genuine client experiences, your clinic can avoid costly legal pitfalls and stand out in a competitive market.

If you have any concerns about your review practices, contact GIVE Consulting at 07437572601 to schedule your consultation and give your clinic the legal peace of mind it deserves.