The codes are published, and reading them is the audit
The unusual feature of advertising compliance, compared with most areas a clinic worries about, is that the rules are written down and freely available. The non-broadcast advertising code sets out what may and may not be said. The provisions relevant to medicines, health and beauty products, and cosmetic interventions are specific rather than general.
Clinics rarely fall foul of these rules through disagreement. They fall foul through never having read them, and through inheriting practice from other clinics that never read them either. The commonest categories of difficulty in this sector are consistent: naming a prescription-only medicine in material directed at the public, unsupported superlatives, before and after images without provenance, and testimonials deployed as evidence.
Prescription-only medicine promotion deserves particular attention because it is the one where the rule is strict and the practice is widespread. The restriction sits in medicines regulation as well as in the advertising codes, and the MHRA Blue Guide is the reference document. A clinic can describe a treatment category. Naming a specific prescription product in consumer-facing material is a different matter, and workarounds using abbreviations or deliberate misspellings do not change the position.
This instrument is a structured way of reading your own material against those published expectations. It is not a substitute for reading them.
How to run the audit
Assemble the material first: every page of the website, the last three months of every social account, any paid advertising currently running, and anything printed. Advertising that exists only in a paid platform is the most often forgotten and the most often problematic, because it is written quickly and seen by the fewest people internally.
Score each criterion against the whole set, taking the worst instance. One post naming a prescription-only medicine scores criterion two 0 for the clinic. This is deliberate: exposure is not averaged.
For criterion three, open your advertising platform's targeting settings and look. Do not score from what was intended.
For criterion ten, check each stated qualification against the relevant public register. Titles are the most common inadvertent failure, particularly where a term implies a registration or specialism that is not held.
For criterion twelve, ask who approved the last social post. If the answer is that the person who wrote it published it, score 0. Approval by the author is not approval.
Record the date and the material set you audited, because the audit is only true of that set.
Common scoring errors
Auditing the website and calling it done. Most exposure in this sector sits on social accounts, where material is published fastest and reviewed least.
Believing an abbreviation solves prescription-only medicine references. The test is whether the public would understand what is meant. Abbreviations, deliberate misspellings and emoji substitutions do not change the answer.
Scoring disclosure by the presence of a tag. Disclosure has to be clear and prominent to the reader. A tag in the twelfth line of a caption is not.
Treating small print as a condition disclosed. Criterion seven asks for equal prominence.
Assuming a supplier's material is safe to republish. Once you publish it, it is your advertisement, whoever wrote it.
Building approval into publishing
The finding that changes the most is criterion twelve. A clinic with a real approval step stops producing new exposure, which means the audit becomes a one-off remediation rather than a recurring clean-up.
Approval does not need to be heavy. A one-page checklist derived from the twelve criteria, a named approver, and a rule that nothing is published without it. The checklist should be short enough to use on a phone, because the material most likely to bypass approval is the post somebody writes between patients.
Two specific rules do most of the work. First, never name a prescription-only medicine in public-facing material. Second, never publish a superlative or a comparison without writing down what supports it. Clinics that adopt only these two find their exposure falls substantially.
Where influencers or third parties post on the clinic's behalf, the arrangement should be written and should require disclosure, because the clinic is responsible for advertising published in its name. The social and influencer disclosure scorecard covers that arrangement in detail.
Then pair this instrument with the claim substantiation checklist, which supplies the evidence criterion one requires, and the prescription-only medicine promotion checklist, which examines criterion two in the depth it warrants.