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[Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] [Music] Patient information aesthetic medicine congresses organized by the College Section. The initiative is not easy, as commented. It stimulates college courses for such a large and important event. And to persist in organizing congresses that, as we are, are rewarded by labor contributions. It is with promise at the forefront that continues a congress that, at 100 degrees, and after which it can be enjoyed, always has an intrinsic value, a little for Sandra. And from a completely different perspective, two pieces of news that have been operated on. The proposal by Jay, which was later approved, to limit influencers from promoting aspects related to aesthetic medicine on social media like Instagram and TikTok. For one, for a mole, but for the other, these types of problems appear, which can generate issues of fraud or areas of intrusion. On the one hand, and last week, we had the news of a conviction for hyaluronic acid infiltrations. A person who did not have the necessary training and qualifications, and who operated in Valencia, and who finally, based on a patient's complaint, or rather, advertising. What are the limits of advertising and regarding intrusion? How has it been? With promises, intrusion on our website, and a direct link where people can report all suspicious situations. Because our department for intrusion and fraud, to help us, stimulates all those initiatives like this one. Thank you very much. I will speak in Castilian on behalf of the reference to the attendees, who are Mrs. Rosa Rodríguez, a lawyer for the Spanish Society of Aesthetic Medicine and the Catalan Society of Aesthetic Doctors. I will continue with the new exhibition, and also for people who do not dominate the language. And I will speak about the patient, how the aesthetic medicine patient is informed, and she will speak about the medical aspect of advertising and regulation. Intrusion is growing disproportionately. Intrusion is growing disproportionately due to the boom that aesthetic medicine is currently experiencing. Intrusion is that person who practices without having the adequate qualifications. The fact that aesthetic centers and dental clinics offering aesthetic medicine are increasing, and they are not medical centers, is very worrying. In such a way that, collectively, they are more numerous than aesthetic medicine clinics themselves. Therefore, today, aesthetic medicine is sufficiently regulated, and the patient knows at all times what they are getting into. But unfortunately, because they go to these centers we have spoken about previously, and due to the trust they place in these professionals, or because they are confident, they do not know that aesthetic medicine can only be performed by a doctor. For this reason, the Spanish Society of Aesthetic Medicine has launched a patient information campaign. It is the campaign of empowering this patient, why? Because an empowered patient is an informed patient, a patient aware of the risks and benefits of aesthetic medicine. And what information do we give the patient? We must give them all those tools so that they can identify risks, choose safety and professionalism in their medical treatments. And what factors should they take into account before starting an aesthetic medicine treatment? What they have to check when they access a center is the academic title, the registration number, and if they have the U-48, which is the health license. In the academic title, they have to check that the doctor attending them is an aesthetic doctor, and on their coat, they should also have identification with their name. And to be able to practice, of course, they must have a degree in medicine. Regarding the registration number, they can check both the name and the number with the Collegiate Medical Organization or with the medical colleges of their autonomous community. In this case, it would be the College of Tarragona. And they must also check that the center is authorized by health authorities, meaning that it has the health license, the U-48, which is specific to aesthetic medicine. Why? Because there are many clinics that have other health licenses, but if they do not have this specific one, the U-48, they cannot practice or perform aesthetic medicine treatments. What advice should we give, or what should the patient know before going to a clinic? They should explain to the doctor what they want to improve, what their expectations are, and above all, that they have understood it well. They should not undergo any treatment where the professional does not explain the risks and complications, because all treatments can have complications. And above all, do not accept treatments that offer miracles and no side effects, because we have said that medicine, as it is medicine, has its risks. Another piece of advice would be that it is the doctor who makes the diagnosis. The doctor advises a series of procedures, and together with the patient, they opt for the most suitable solution, the least invasive one. Along with that physical examination, which must be exhaustive of the area to be treated, taking photographs is very important. Why? Because these are an important part of the medical history and also help us to evaluate the evolution of the treatment and the final result. If the patient is not completely convinced of what is going to be done, we always advise not to proceed, but to seek a second opinion so that they are sure that what is being proposed is what they really need or want to improve. Other important advice: sign the informed consent. It is a legal document in which the patient's information is written down, and above all, all the risks that the treatment could entail. One should also be careful with those who promise too much. That is, in aesthetic medicine, there are no miracles or magic. Above all, the patient must trust the aesthetic medicine expert, and above all, and very importantly, be distrustful of raffles, discounts, and promotions for both facial and body treatments. Why? Because they are contrary to the ethical code of the medical profession. We are doctors, not estheticians with a title, and that must be made clear. Patient safety is our highest priority. And why do we say this? Because we are increasingly receiving a greater number of adverse effects from treatments performed by non-medical personnel. Medicine is not harmless, and aesthetics, with it, carries its complications and contraindications. Therefore, in addition to empowering the patient, what we want to promote or appeal to is safe aesthetic medicine. For this reason, the Spanish Society of Aesthetic Medicine has also created an Instagram account called "Medicina Estética Segura" (Safe Aesthetic Medicine), which is specifically designed to inform the patient and to raise awareness among the population. The messages they use are usually impactful, with images or short phrases, because we already know that on social media, when a recording or communication lasts more than 15 seconds or is a long paragraph, people lose interest and do not pay attention. In this case, we see two cases. One, for example, we are informing the patient without being aggressive, which is correct in aesthetic medicine. That is, the products applied to the patient must have their marking; they must be given the sticker so that the patient knows what is being put into their body, even so that if they later go to another doctor, this doctor can see that what the patient has is not contraindicated and can act on it without danger. Why do we say "demonstrable quality"? Because it is known that in this world there is also piracy, there is smuggling, online purchases, counterfeiting, and all of this also leads to a greater risk of adverse effects, and it is the doctor who knows how to treat that adverse effect, meaning only the doctor can and knows how to solve it. Hello Rosa, another example would be, for instance, that the FDA warns patients not to use, or estheticians not to use, needle-free devices that promote lip augmentation with hyaluronic acid. Because since it is painless, the patient already thinks it is safe, it won't hurt, and on the contrary, disasters are occurring, very unpleasant ones. But of course, if the patient is not informed, they don't know. So they trust their esthetician who says, "Look, I've brought a new treatment, do you want to try it? It doesn't hurt," and the patient believes it. Therefore, what is our mission? To encourage the patient to follow this account because we need them to know about medicine that is safe and to know where its limitations are. Even we ourselves as doctors should share on our social media some stories of what they post to increase the diffusion of safe aesthetic medicine and also so that they all have knowledge of the existence of this account. And what do the acronyms MES mean? On the one hand, M for Medicine. Aesthetic medicine is a medical discipline dedicated to preventing and treating alterations and pathologies, applying techniques to improve aesthetics and beauty, promoting longevity and health, and also the physical and mental well-being of all patients. E for Aesthetics, of course, because one of the objectives of aesthetic medicine is to apply techniques to improve aesthetics and beauty, but always so that the patient feels better and thus their self-esteem increases. And S for Safe. Aesthetic medicine can only be safe when the health and well-being of people are guaranteed, and that can only be achieved when it is carried out by accredited and well-trained aesthetic doctors. And to conclude, I would say that I never tire of repeating that aesthetic medicine, even though it has "aesthetic" in its name, is medicine, and as such, can only be performed by well-trained doctors. Thank you very much. Well, now I will pass you on to Rosa Rodríguez, who is a lawyer for the Spanish Society of Aesthetic Medicine and the Catalan Society of Aesthetic Doctors of Catalonia, and she will talk to us a little about advertising on social media, regarding advertising and regulation. [Music] [Music] [Music] [Music] [Music] [Music] Phenomenal. Well, good morning everyone. Thank you very much to the College of Physicians of Tarragona for the invitation, and of course, to the College Section of Aesthetic Medicine. Well, I think you have already introduced me. I am Rosa Rodríguez, a healthcare lawyer. I've been doing this for a few years, which you can't tell because aesthetic medicine treats me very well, but I've been doing it for a while. You have asked me to talk about many very interesting and somewhat tricky things. I'm glad. I know I have legal colleagues who will support me in certain difficult matters. I will talk about the regulation of medical devices. You have combined it with intrusion, and I think with very good judgment, and we will talk about it. I will talk about advertising, which is currently a very, very difficult and conflictive topic in certain health departments. Catalonia is not the worst, I'll tell you that now. We are currently in Galicia, it's terrible. And then social media, social media, which, well, to talk a little if you want about the ethical code, and well, as we were talking about marketing within the talk, it seems that talking about social media is always useful for colleagues, for members, to try to do things right, as you were saying earlier. Well, that's quality aesthetic medicine, and quality also in terms of social media. And well, without further ado, I've done it in reverse. Thank you. Well, I'll start talking about the regulation of medical devices. This regulation is from 2017, but it's still causing a stir today, in 2023. What's happening with this regulation? This regulation is from 2017, and it talks about medical devices from Europe. What they tell us is, we want to do everything perfectly, and there are a series of products that we don't really consider medical devices, but because they don't have a medical purpose, we want them to be well regulated. So, what we're going to do is, we're going to put them within the regulation, but in a separate annex. This is Annex 16, which I've placed there. And how does it affect us? It affects surgery and aesthetic medicine directly, absolutely directly. I've listed there the products included in Annex 16 of the medical device regulation, and as you will see, the first one talks about analyses, basically. The second one talks about filling implants, which directly affects aesthetic medicine. The third one will talk about all equipment for liposuction. And finally, well, not finally, the fifth one that directly affects aesthetic medicine is all equipment that emits electromagnetic radiation, where we have, of course, laser equipment, IPLs, radiofrequency, and so on. And what does the regulation tell us? Well, what we have to do now with this Annex 16 is, we are going to create specific regulations, we are going to form a commission, and we are going to try to provide a draft to see how we develop it. Oh, excuse me, I'm going in reverse. They release a first draft. I must say that some scientific societies of medicine, before this draft appeared, already said, "Hey, if you're going to form a commission, we want to participate." The Spanish Society of Aesthetic Medicine was there, as well as the Spanish Society of Medical-Surgical Laser, which also said, "I want to be present." We were never called, and suddenly this draft appears. This draft was met with clear opposition from absolutely many scientific societies. I've put it very small there, just for reference: the Spanish Society of Aesthetic Medicine, the Society of Medical-Surgical Laser, the Academy of Dermatology, Facial Plastic Surgery. I mean, there were not only in Spain. Well, it's true that we also talked to each other in different countries, and so on. All the people who could be affected, all the scientific societies that could be affected, we talked to each other. Many doctors also, many local scientific societies also sent these types of letters, and also many doctors, on the contrary, many estheticians, many nurses, many who wrote saying that it was good. What were the reasons for opposition? Basically, I'll list the ones from SEME, although the laser ones also went through other channels. The first thing that was said was that the title was absolutely incorrect because one could not speak of products without a foreseen medical purpose. It should have been spoken of either that they always had to... this is what SEME maintained... that there was always a medical purpose, which could be for cure or improvement, but in any case, there was always a medical purpose behind it. But well, at least what SEME said is, the minimum you can do is medical devices with or without therapeutic purpose, so we started off badly directly with the title. Subsequently, what was said was that it had to be absolutely always employed by a doctor. Then we said, "Hey, be careful, because, for example, the FDA does not only take into account safety, which is fundamental here due to all the adverse effects that all these devices can cause us, but also efficacy must be taken into account. Because, for example, in the case of lasers, when it talked about lasers, it talked about domestic products that are received at home. So, well, we have to see what efficacy they can have, because to be safe, they might not be effective. So these are issues that had to be taken into account. Then it was also said that it was not normal, that the medical societies that had appeared and the doctors to make this draft had not been taken into account, because it was obvious that it was not made by doctors. And well, and that the general regulations that dealt with all these types of products and so on in the different countries had not been taken into account either. Well, all of these appear until, suddenly, an implementing regulation appears, yes, definitive. This appears in December '22, so it takes effect on June 22nd of this year, which is why everyone is a bit nervous, quite nervous. What can be done? Who can do what? Well, here's a bit about how it has been resolved by this implementing regulation. I'll go through the easy part, what affects surgery more. On the one hand, we have everything that could have to do with prostheses, and there it is clearly stated: the product should only be implanted in an appropriate healthcare setting, and the implantation must always be performed by a doctor. Now, let's go to the topic of liposuction equipment. We are in exactly the same situation. It also tells us that it must always be with a doctor, who can then have an assistant who can be a doctor or a third party, but in any case, always by a doctor. So far, we have two out of four, not bad. Let's go to lasers. It wasn't too bad. Here, when we talk about lasers, what it does tell us is, be careful, except for hair removal, meaning hair removal, which is also not for a pathology, meaning not for intrusion. A medical report will be necessary. It's not bad, because at least there is control. Now we'll see what those controls are, how they will try to bypass those medical controls, those medical reports, or how it's done well or not. I am aware that the Spanish Society of Medical-Surgical Laser has sent this specific paragraph or this part of the implementing regulation to the health departments so that this is known. But the truth is that the regulation does state that manufacturers will have to warn all users of these types of devices that they need this report. And now, as you have seen, I have gone from more to less. Well, let's go to what would be filling implants, and here we have the problem that it should not be a problem if things were read properly. What does it tell us? They can only be administered by duly trained healthcare professionals who are qualified or accredited, or in accordance with national legislation. What is the problem? It doesn't say doctor, it says healthcare professional. A nurse is a healthcare professional, of course. But the issue is to finish reading the sentence, and it says "qualified and accredited in accordance with national legislation," and this is the part they are not reading, and that's why they are telling us that on the 22nd everything changes, and that these products can be used by nurses. Here there are at least two lawyers. We will all see that for us not to starve, there must always be two lawyers in a court, so this is an interpretation. I believe that this interpretation that we are giving is the real reading of what the norm says, but also, as you know, the Spanish Society of Aesthetic Medicine, in response to a resolution in 2017 from the General Council of Nursing, which stated that since aesthetic medicine was without regulation, they would carry out a series of medical aesthetic treatments. And at that time, the Superior Court of Justice, meaning the lawsuit began, SEME also filed a lawsuit, SECRE, plastic surgeons also filed a lawsuit, dentists because they did things related to the mouth, also the OMC, of course. Then the Court of Justice of Madrid made it very clear, and not only made it very clear that it is true that it is an administrative procedure, it is not an intrusion procedure, we are not in a criminal matter, but it is also true that what it says is that you, as a college, do not have that competence, you cannot regulate, you can organize your nursing profession, not regulate. But the truth is that it goes a little further, and it does tell us that all these procedures, including, of course, facial and body infiltrations, toxins, hyaluronic acid, and so on, are faculties of the doctor. What happens is that, not content with that, nursing goes to the Supreme Court, and the Supreme Court, in a ruling from 2021, which for us is the day before yesterday because this is from yesterday, clearly states that the fact that there is no specialty does not mean that this council, the nursing council, can say that medical treatments can be performed by non-medical personnel. It says that it is a space that the law reserves in general for medical professionals. What problem do we have then? If all this seems very clear, the problem we have is, well, obviously, there are many courses today for nurses, training courses that say they offer courses. First, it was aesthetic medicine, which the name itself was absolutely shocking. Now they talk about dermo-aesthetic nursing. And they base it on things. First, and I'm surprised because they have been advised by lawyers. First, they said that this regulation contradicts what our Supreme Court says, and nothing could be further from the truth, especially since we have seen that the regulation states that these medical devices will be for healthcare professionals with qualification and accreditation according to their legislation. So, our legislation, and I'm not saying it, the Supreme Court tells us, what it says is that it is reserved for doctors. In what else do they take refuge? In Article 79 of Royal Decree 1/15, they say, "I can prescribe." They have started with the issue of prescription and say, "I can prescribe." Well, be careful, you cannot prescribe carelessly. You will be able to prescribe medications that do not require a medical prescription, those for which a protocol has been established by colleges of physicians, colleges of nurses, the Ministry, etc., and for medical devices, it is true, independently for your profession, for your profession. And that is the part that, again, in a way, they are closing off and losing. So, it's a bit about this because I said it once in a talk not too long ago when I talked about this, and nobody believed me, but I said, "I'm going to go to ChatGPT and ask it what it tells me." And look what it answers. I've become very loyal to it, I who am not very intelligent, but it says: "The nursing capacity to administer hyaluronic acid injections depends on specific regulations and laws in your country and state." So, it has read the regulation because it's spot on. And then it says: "If you are considering a hyaluronic acid treatment, I recommend that you consult with a medical professional." Well, it's like being loyal, isn't it? I think, because it's great. So, this is a bit of what I wanted to tell you. I don't have much more to tell you about this topic of regulation and intrusion. I think the issue is clear, but it is true that the fact that it is massive and also with the support of their councils, the National Council of Nursing, well, and all the local ones, it's a bit why they are... I don't know if it's also the fact that all the training, I understand, generates a lot of money too, so, and well, in the end, they are also trying to find different avenues for their own members, I understand, for training, for work, and so on, which would be very legitimate, and it is also important that there is that multidisciplinary work. There are fantastic nurses, and we should work, collaborate, I mean, within what would be their field. So, this is a bit of the opinion, in view of what the law is telling us and what we have been fighting for in the courts. I am aware that they filed an appeal with the Constitutional Court, but unless I am mistaken, they have not admitted it because quite some time has passed. The Constitutional Court is not very inclined to admit things easily. So, unless I am mistaken, it has not been admitted. So, a priori, these rulings that I have mentioned should be final. But of course, since I am in another part, if it is not admitted, it has not been transferred to me, so I do not have direct knowledge, but it seems that it has not been admitted. So, a bit of the situation we are in. They are very united, and I must say this: you are very few. I must say it, because the specialties have broken you. And I have been a lawyer for 22 years now at SEME, and if not, SEME is now very good with plastic surgeons, but plastic surgeons are not good with, I don't know, dermatologists. That's how we are. So, of course, however, every time I see other groups, estheticians, nurses, dentists, I see such an absolute union that, of course, in the end, they sweep us away. But well, at least what is certain is that the laws and the courts, for now, to date, are giving us the reason. And well, a bit about this regarding regulations. I'll move on to advertising, another topic that you have left me the best for today. Health advertising. This is a topic that is being absolutely debated everywhere, because two years ago, we are in '23, in '21, in August '21, doctors started receiving letters, many aesthetic doctors, many dermatologists, I am aware, started receiving letters about advertising issues, to clearly state that it was being done incorrectly and that much reference, especially to medications, had to be withdrawn. And at one point, initially, they also talked about medical devices. So, this is a bit of the situation. This is the legislation we have. Well, I'll talk about the General Advertising Law. Basically, what it tells us is the definition of advertising, and I think it's the most important thing, where we need to be. What is advertising and what is information? That's where, I think, the crux of the matter lies. It also tells us a bit about... it refers us, of course, to all health-related matters to specific norms for health advertising. Then we go to Royal Decree 1907/96, which is for those products with a claimed health purpose. Here it tells us that we must be cautious with veracity, that we must not give an image of a sure, definitive cure, that we cannot use testimonials from people that may incite or promote consumption. Royal Decree 1416 of '94 on human medicines, which clearly tells us, and here we are talking about botulinum toxin, PRP, where it tells us that we cannot advertise prescription medicines dispensed directly by a doctor. Royal Decree on Medical Devices of 2009, which also talks about the fact that testimonials from people cannot be used that may amplify, that may promote the fact that these products are used. Royal Legislative Decree 115, which you know, is about guarantees, well, about guarantees and rational use of medicines and medical devices, which, well, says pretty much the same thing, that prescription medicines cannot be used, and it even talks about medical devices, and this is causing us a lot of problems in Galicia, where it is direct prescription and dispensing by the healthcare professional, they cannot be advertised either. It also tells us that we cannot use testimonials or real patients. And then, finally, and this one I think is quite good, is Law 13/22 of July last year, General Audiovisual Communication Law, which talks about influencers. It's true that it doesn't talk about it as in-depth as in France, which you all surely know, where they have decided that influencers cannot talk about health matters in any way. But the truth is that this one does limit, Article 123, I think, or 13 something, the article does tell us that we must be careful, that we will not be able to advertise medicines, medical devices, or treatments if they do not clearly comply with the regulations. So, as conclusions, the most important thing: advertising or information. This is a huge problem we are having. What is transmitted to us by health authorities, specifically from Catalonia, is that they tell us: "You went too far." What they tell us is, "We were letting you advertise PRP, botulinum toxin, certain things in the sense of providing information, for example, about your range of services." But the moment it started to involve prices, doing all sorts of advertising, we had to cut it, and they cut it, but they cut it very, very deeply, very abruptly, and so on. So, we have reached the point of telling them, "But how can you tell a scientific society that it has to remove all terms, eliminate all documents where the term 'botulinum toxin' appears?" This is a problem because then I will have a series of doctors who will go to Doctor Google and find all the information from someone who doesn't care at all about breaking the rules, and thank goodness if it's a doctor, or who knows where. So, to that extent, I will tell you that SEME has made us remove all information. It is a scientific society, it does not have a profit motive, and of course, the only thing it does regarding botulinum toxin and so on is training courses for its members. So, we had to eliminate everything. It is true that they leave us some articles and so on, and always with disclaimers, but at least they have left us that. So, in the end, the question is, well, what is advertising? Advertising, I put it there, is what the law says: "any form of communication made by a natural or legal person, public or private, in the exercise of a commercial activity, with the aim of promoting, directly or indirectly, the contracting of a service." So, of course, there is a very fine line in many cases. So, what they have decided is that what they previously considered all information, as long as what you were advertising clearly coincided with your range of services, has now been considered advertising, and therefore, they have given us an absolute cut at all levels. This that I put here, "What is information?" This was put in the SEME congress, Department of Health, okay? "Disseminating treatment novelties, providing information to improve quality of life, promoting our brand, informing about the range of services." But of course, the range of services must always be understood while respecting the regulations, so I can no longer say that I perform PRP in my clinic. And there is also something that is a bit of a trick: "Disseminating treatment novelties." Well, be careful, because we have had a doctor who received the famous letter, who removed absolutely everything, and then published a note on a blog saying, "I'm coming from a fantastic botulinum toxin course at INCAS," and they forced him to remove it. They forced him to remove it. So, well, if disseminating treatment novelties should be considered information, but he was forced to remove it. The bad news, I don't know if to start with the bad or the good. The bad news is that the penalty is 90,000 euros and upwards, and they are already starting. The good news is that it does not have a revenue-generating purpose. It has not had it to date. What they do is send letters. If they see good faith and it is removed, they don't send another letter. And when they see that there are still some things left, but that there has been good faith, or that there has been an error, or that perhaps it is an article from a long time ago and it could not be seen, they send a second letter. But it is true, for example, when someone removes the word "Botox" but puts "BTX," removes "PRP" but puts "Vampire," then fines are imposed. So, well, we talk about 50,000 euros, which obviously closes a clinic. So, let's be careful. Then, of course, it is very difficult. I am a lawyer for many doctors throughout Spain, and they ask me, "What about the one next door? He appears on buses with Botox." That is the risk that each one wants to take. Up to that point, what I have to say is what the legislation is, what they tell us, and what the spirit of it is. The spirit of the law, which they taught us so much in college, well, it's there, and those interpretations, well, they will depend, but I think the process has been that: being very lax in interpretation to being extremely strict. Currently, I insist, the problem is also that it will depend a bit on the communities. The most affected will be Madrid, Catalonia, then Andalusia started a bit, and now Galicia is something tremendous, they are not even letting them advertise medical devices. I've put a couple of articles from the ethical code there. I think Article 893 is very good: "Medical advertising must not use public figures or real patients." I say this because this is a topic of before and afters that can be somewhat dubious. They talk about many other things, that it must be objective, prudent, truthful, not to foster misleading hopes of relief, cure. The law also said that prizes, contests, and so on are not allowed. We all know this very well, but this new ethical code of '22, for example, I think it's important. It's true that the previous code, from '11, also talked a bit about images, saying that they should always be anonymous and simply used for scientific training and knowledge purposes, and so on. But now it's a bit clearer in this regard. And another one that I think is good, which is outside the advertising part but should be taken into account, is: "Medical dentistry, client acquisition through advertising that includes service prices." So, here we always play with terms. That's why lawyers are a bit... it's contrary when it's for client acquisition. So, well, it doesn't say it's contrary to putting prices. It's contrary if it's for this. It's the same as the previous one, which tells us that as a means of inducing consumption. So, if I put before and after, maybe it's not a means of inducing consumption. That is, we always play with that ambiguity that is very useful for lawyers to defend one position or another. But well, at least it's important that we think about it and take it into account. So, very quickly, medications. There I tell you that it is totally excluded, all these prescription and dispensing medications. So, in our case, especially botulinum toxin and PRP, what is being done is trying to re-educate. And in the case of botulinum toxin, it's talking about treatments for dynamic expression wrinkles, for example. And in the case of PRP, regenerative techniques are being used. So, well, in the end, it will be about educating. We see it as very difficult, but when we had to remove the term "Botox" for "botulinum toxin," that was a crisis. But in the end, people know what botulinum toxin is, and they make a slight difference, or at least they know it's a "Botox," so with that, it's quite a lot. Well, let's see if we are capable of doing it properly now. Then, medical devices. There I tell you that the use of brands is prohibited. So, we can use, for example, that we are going to do threads, that we are going to do fillers, and so on. But be careful here. And for now, in Madrid, in '22, not subsequently, apparently, a consultation was made with the agency, and they say yes. But in Galicia, they are already telling us no, that it will be exactly the same treatment as for medications, according to Royal Legislative Decree 115. It's exactly the same treatment they are giving to brands, or rather, to medications. So, maybe soon they won't let us do this either. But well, for now, in principle, the general criterion is that yes, medical devices can be used without mentioning brands, without naming them. Of course, all these products must be for treatments that we have in our range of services. Raffles, no, absolutely not. But not only does the ethical code say so, the law also says so. This is an absolute struggle. When Black Friday comes, Christmas, and so on, it's like I start getting flooded with them. Well, first they reach me, and second, they reach me from scientific societies saying, "Absolutely not." Well, we certainly report it because we think that in the end, you are vulgarizing, in a way. Aesthetic medicine, as Esther rightly said, is medicine first, and then aesthetics, but first it is medicine, and we should not trivialize it. Photos, before and after. Well, I'll leave it there for now. I have absolutely no record of any sanction for a before and after, but it is true, and I have read it to you before, that they are telling us that when they publish images or photographs, they must have a clear scientific and educational purpose. And the previous article I told you also stated that real patients should not be used as a form of incitement. So, well, if we put it in a section where we are explaining how good threads look, how they lift, and so on, and I have the before and after photo, and I have...
It is certainly true that it is certainly true that authorization. There is no doubt. And if, on top of that, I can not show the patient, even if I have authorization, and I do everything, everything very well, then perhaps we will be free, but well, it's a bit of the same thing again: advertising or information, where do we find ourselves? But well, I have no record of any kind of sanction to date, neither dental nor in health departments. Prices, well, I've also read them to you before, it is supposed, according to the code of ethics, when it is to attract clients, it should not be used either, but the truth is that I also have no record of any rule that is prohibiting it, and a priori I also have no knowledge of any kind of sanction. And this is the last thing, the result, the result, we must not guarantee what it seems. Who is guaranteeing? Well, every day, that is, definitive hair removal, that is guaranteeing a result. Any comment is that there are many comments, now it doesn't come to mind, well, it comes to mind, it comes to mind. When you went to a plastic surgeon and they took a series of photos and you left with a nose and you took that nose home in the photo, and then they operated on you, they left you fantastic, but with a different one than the one in the photo. That is guaranteeing a result. So please, we have spent half our lives to achieve that aesthetic medicine, aesthetic surgery, is not considered to have an obligation of result. But of course, if we are giving that result and on top of that we are advertising it on our website, we will certainly be obliged to give that result, but not because we have an obligation as doctors, but we have a contractual obligation because we are advertising it, okay? And apart from that, what the regulations we have seen, both legal and ethical, are telling us is that this information cannot be given as a sure cure. So, well, let's be very careful with these things. And to finish, and before starting on social networks, it has a lot to do with social networks, but a lot to do with advertising, which is one of the most important parts of social networks, which I will then skip so I can finish quickly. It is very important that we take into account the issue of marketing, because the marketing people do their job very well, very well, but they don't necessarily know your code of ethics. I mean, in the end, it is the doctors who have to do that supervision, that control, it is they who can also, at a given moment, receive some kind of sanction, with which it is very important that there is that communication with the marketing people, that they do their job, which they will do phenomenally, and that you, as doctors, review all these things. And I say this, but look, the World Medical Association says it. It's very small, but the point is that when it talks about social networks, it basically talks about colors having meaning. You see there's orange, green, and blue. Well, I mean, they are chosen at random. I mean, but what the World Medical Association is telling us when we are talking about social networks are three things, which are the most important things on social networks: responsibility, confidentiality, and security. That is, anything we might be doing on social networks will be considered a medical act, with which we must be absolutely careful in the statements we make. On the other hand, responsibility is not the law, the city without law. We are talking about the fact that on social networks, of course, all regulations apply, and it can even be more dangerous because the dissemination goes much further. And then, of course, confidentiality. Let's see if we have it within our clinic, within our consultation with the patient, we certainly have to have it even more so when we are on social networks. So, well, all of this that looks very small, but more or less each of these sections talks about those three words, which is what I think is most important. When we finish the topic of social networks, the most important thing is to comply with the law. Keep in mind that a doctor is like King Midas, meaning that everything they touch turns into a medical act, so let's be very careful with the things we are saying, and that, and let's be very careful because we are dealing with people with very sensitive data, with very important data, with images of our patients, and we have to ensure professional secrecy even more so when we are on social networks. And this, which I'm sure you know very well because it was made by you, and I find it fantastic. Of course, in 2011, we didn't have a code of ethics that talked about social networks. It made mention. Well, moreover, when telemedicine was discussed, it was said that it was totally prohibited, except perhaps for a second opinion as an auxiliary measure. So this style manual for doctors and medical students was created, which I find fantastic, and every time I talk about social networks, I follow it because I find it very, very good. Now, moreover, it is already supported by the code of ethics of 2022, which now does have a complete chapter, so we are doing quite well up to there. So I'm following the little cheese of confidentiality and medical secrecy a bit. Well, when we talk about social networks, we have to keep one thing in mind. A study has been done, I read it from a doctor, I found it fantastic. Eight out of 10 patients, eight, when they go to the consultation, they have already read everything. They know who their doctor is, they know what they have, and what they need to be given. So we have to be absolutely extremely careful, because social networks are fantastic, they are very good, they give us brand, they give us visibility, they give us networking, they help us to stay updated, often also, which is an obligation of yours, in pharmacovigilance, for example, that you have to have all the information and so on. But we have to be absolutely extremely careful because things can happen to us that we don't, that, well, that we have to be careful in the use of these social networks, especially with some, because social networks encompass everything. They encompass an email, which doctors are less accustomed to, lawyers use it permanently. I like it a lot because I find it asynchronous, not, not, not so intrusive, right? Because you can reply whenever you want, everything goes more calmly, you can transfer information, it has its problems, it has its problems because you can find that you have made a mistake and sent it to a third party and so on. But well, then you have WhatsApp, which is indeed very dangerous, and I'm going to talk to you a little bit about each of these issues of this little cheese of how careful we can be in terms of confidentiality and secrecy. There I put some of the articles that can talk about these issues. The issue of patient anonymity, look, well, well, if we have to be especially careful when we are on social networks, because we can be talking to someone, or we can be showing someone, or we can upload something to Instagram, for example. But in the end, what happens with Instagram, with Facebook, and so on, is that all of that will expand. The moment I upload it, there is no longer any control. So we have to be very careful. I put it there. It is very important to know the privacy conditions of each social network, because look, there is some that is who can see my Instagram, my friends, my friends' friends, my friends' friends' friends. Each of the conditions, each of the social networks sets conditions. So it is very important that we take this into account. It is also very important that I am not my colleagues. I, I, I have a social network and I don't go out in a robe, but I tell you that I don't know how many doctors go out in their scrubs, in their operating room pajamas, and go out with that image, but then having a barbecue. Well, I think it's fine, but if there are seven small bottles of beer and tomorrow you're going to operate on me, maybe I don't feel like it. So let's try to be a little, a little careful to see if we have, at a given moment, perhaps a private social network, but truly private, and another that can be more public for other things, and let's be very careful with the use and also with that. Look, here I have a tremendous example. We surgeons, as you know, many do not have their own practice, they are going to different centers, many in aesthetic medicine, plastic surgeons, who, well, a center asks them for some before photos, before and after photos, so that they can post them. If I have one, I even have authorization and everything, fantastic. And the image, well, in that image, the patient should not be visible, because it was about breasts. Well, what is visible is a small tattoo, very small, on an arm. So the woman identifies herself and says, but do you have authorization? Well, no, because that woman had given authorization for those photos in the clinic where that surgeon had operated on her, but not in a different clinic. That is, the surgeon did not have it. So let's be very careful. Let's try not to identify our patients and be careful, because these kinds of things tend to happen. So it is quite important that we always, always try to keep the patient anonymous. An example that this manual gives, for instance, was very funny, and it was about an X-ray. Of course, if it's an X-ray of a patient in a very small town and their initials are, say, Rosa Rodríguez Arias, RRA, and it says birth and a couple more things, and we are in a very small town, then it might be possible to guess who it could have been. So let's be very careful, because confidentiality is very important, okay? We continue with the second piece of advice: virtual patients. As I was saying before, everything done by a doctor is a medical act, so here we have to be very careful. So what do we have to do with virtual patients? If a virtual patient comes to us, we don't know them at all, we do nothing, we have absolutely no obligation to provide coverage. What we can do is direct them to a doctor, to a consultation, we can disseminate some generic information, but that's where we stop. And if, of course, the person who contacts us on social networks is a patient, a friend, a relative, then perhaps what we can do is reply privately or tell them to come to the consultation and so on. And why do I tell you this? Because of this, because of what I'm showing you here. If we have a consultation on social networks, we are not going to see the patient, we are not going to perceive their symptoms, we are not going to consult their medical history, we are not going to do tests, and furthermore, the information that the patient gives us may be biased, but not because they want to, because perhaps they are telling us, "A little spot has appeared," and they are not telling us that they have a headache or that they have another spot a little bigger, a little higher, or something that we would be looking for. What happens is that, without all this information, I am going to make a diagnostic error, a wrong prescription, and therefore incur malpractice. That is what we have to be careful about. This, for example, that I was talking about before, the different WhatsApps. For example, WhatsApp is for us to say, "You have an appointment tomorrow," but not for us to have consultations and reply to them, because we don't have this medical history. Because they tell us, "Oh, you just gave me a toxin, can I take an aspirin?" "Yes, yes, you can take it." Well, perhaps that person is allergic, and if I had seen their medical history, look, this is obvious, because someone allergic will know that they are. But I mean, those kinds of issues can arise. So let's be very careful with those kinds of issues. WhatsApps, for example, are dangerous. Well, apart from the fact that WhatsApp is like imminent, and you are almost stressed because the patient writes to you and you have to reply almost immediately. So let's be very careful with those social networks. I was saying, each one has its own thing. Twitter is fantastic for announcing that there's a talk here today, but be careful with retweets. Sometimes I say, this doctor couldn't have retweeted this. They only read the title, because then you open it and you say, "What barbarity!" I'm sure they didn't read it, they saw the title and said, "Boom!" So each one has its own thing, and each one is very good, it can help us a lot, but well, working. LinkedIn is very good, but also for defaming you in front of those you don't want to be defamed in front of, all your colleagues or the pope of aesthetic medicine. So let's be very careful with all these uses. I'm almost done. The care of the doctor's attitude and image as a user on social networks. Well, well, doctors have this image of generosity, of, well, you have a very positive image in society. So, well, it is very important that you take care to avoid insensitive, frivolous attitudes. We have them every day. Aesthetic medicine is something, it's something terrible. Well, if I give examples, it will go away, who it belongs to, but yes, you get a helicopter lowering a man with an elixir of life. Well, I mean, we cannot, we cannot trivialize in this way. You are doctors, and that is the most important thing at all times. So, prudence, prestige of the profession, and not forgetting that a doctor never stops being one. The use of new technologies in direct consultation. This is also important, because we have to think about the relationship of trust between doctor and patient. So if I am in my consultation, not attending to the patient, looking at or showing them photos of other patients and so on, there can even be accidents, because perhaps I leave the consultation for a moment, a photo appears on my phone with the image of the patient's neighbor, who says, "Oh, I didn't know this person came here, that they were having these treatments." So things can happen, apart from the fact that that patient will have the feeling that we are not listening to them, that we are not concerned about them. So social networks, a priori, must be left out when I am in my consultation. Responsibility for medical information disseminated. I like it a lot, I haven't put it here, but it's not because it's not about advertising, but the code of ethics, article, I think it's 79 or 79.3, I think it is, which clearly says, "Be careful with publications by doctors who release those publications when they do not yet have sufficient solvency nor has their efficacy been accredited and so on." So let's be very careful with the information we are giving, because I insist, everything you touch turns into a medical act, so be responsible for these kinds of issues. So, clear, truthful, balanced information, always for the benefit of health. Responsibility, well, that derives from a face-to-face medical act is exactly the same as that which is disseminated through social networks. It must be prudent. We now move on to relationships between colleagues. Well, fraternity is one of the principles in your code of ethics, no doubt. So, well, especially be careful, respectful, which is something that should hardly even appear, and that we should all be, and in all areas, okay? But it is important that we have it and that we take into account that. No disqualifications, no pejorative expressions. The previous one, as it didn't talk about social networks, did say not to talk in front of the patient, the patient's family. So, of course, imagine the loudspeaker that social networks represent when I'm going to talk about a colleague in front of other colleagues, in front of many people, it will be seen. And well, of course, avoid allusions to personal matters. It's different if we, in some way, report a colleague who is doing something wrong through the appropriate channels, in this case, coming here to the college of doctors. That is not going against the principle of fraternity, and that is also correct and should be done. But well, that information through social networks and so on, that is what should not be done. Advertising and marketing. I'm going to skip it. I think not, because we've already talked enough about it. Here it is important to mention, especially about marketing, that we review it, that you doctors review the marketing people, who do not have the obligation or should not know it, or at least inform them. Take this, this is the code of ethics, you have to read it, but above all, you have to be very careful for that reason that I tell you, it's that you go out of your consultation in scrubs, and in operating room pajamas. All doctors, I mean, there isn't a doctor who doesn't dress appropriately for the occasion on social networks. So, well, if you want to give that image of being doctors, then behave like the doctors you are. I'm finishing now. This is the very last thing. I don't know if I'm going too fast or too slow. Defense of the doctor against attacks on social networks. I include this phrase because doctors complain a lot, because they told me, "Of course, you tell us what we have to do to do it well, but also I am receiving many complaints from patients or non-patients, because often it happens that suddenly someone posts a comment anonymously or through patients who are not yours, whom you don't know, and what you do is go from a 5 on Google to a 1 suddenly. So what can we do against attacks from patients?" Well, first, and the easiest, it seems, is to go for an extrajudicial action. The first thing is to try to approach the patient. Well, perhaps send a registered letter and so on, try to soften it and tell them that your intimacy, your personal and professional honor, and so on, may be being violated. If not, we can also try to go to the platform and ask the platform to remove it. They will review it. If they consider it freedom of expression, and they are also very lax in thinking that it is always freedom of expression, they will leave it. But well, we also have that possibility. With that right to be forgotten, perhaps we can go to the data protection agency when we believe it is really burdensome, to see if they do something to demand that the platform remove it. If not, what can we do? Civil actions, a rectification lawsuit, seven calendar days to be able to go and try to get that text removed and put another text, because, of course, there is a problem here. The problem we have is that what the marketing person will want is to post a response, but it will be a very limited response. I will not be able to say, "Look, you are my patient and I have done this, this, and this," because then I am revealing all the medical information that I cannot reveal. So sometimes it's better to be cautious and say nothing. Another thing is to reply to someone saying, "Excuse me, I don't know you, you are making a comment about my clinic and you have never come to my clinic," or things like that. But at least always without revealing. So, well, here we also have the possibility in civil law to go for a rectification lawsuit, a lawsuit for violation of honor, intimacy, and image. If it is very, very serious, when they are already slandering us or committing any other crime, coercion, and so on, we can go to criminal court, a complaint to the police station, and even to the investigating courts, which exist, which exist. Because I have seen people saying, "He has ruined my life in hair transplantation, for example. He has ruined my life. I'm going to his house, I'm going to burn his house," and so on. Well, this must be reported, no doubt, and also at the police station, and the police will be able to see the computer chips, and of course, they will be able to know. For example, in a case we had in Valencia, coincidentally it was someone, a university official. But well, it was relatively easy. A person who had been a patient of that doctor, who coincidentally was a university official, I mention that because it was an IP that could be shared. But the truth is that it all pointed in the same direction. So, yes, they can do this, and these can also be ways for doctors to defend themselves, because it is true that we try to give you talks so that you do it very well, but sometimes you also have to defend yourselves from these situations. So, well, nothing, evaluate with your lawyer the seriousness that sometimes bothers you, but a patient can come and say, "I didn't like it at all." That's freedom of expression. They didn't like it, they didn't like it. There's little we can do. Those are the most damaging, right? But well, it's another thing if they say, "He left me with my eye closed," when it's not true, or when they are slandering me or anything else. So the lawyer will assess whether there is indeed honor, whether there is a violation of any kind or not, and which route would be the most appropriate for a more or less quick response. And that's all. As I said, social networks, security, confidentiality, responsibility. With these three things, things are done, I think, quite, quite well. And that's all. Thank you very much for inviting me. I don't know if I spoke too fast. I'm sorry. It's very common. And well, and then we'll chat from now on, whatever you want. Do you have questions? It's about the first part of the intervention, about the 2022 regulation, when we talked about health professions that accredit capacity in training, in accordance with national legislation. Yes, of course. What national legislation? Because if we enter the LOPS, it's sometimes very generic, and many health professionals can consider themselves qualified with a certain training. Well, that national legislation is very generic, it's not that terminology. So it's true, but however, it is what the Superior Court of Justice of Madrid and the Supreme Court have based themselves on. The LOPS have clearly stated that the definition of doctor and nurse provided the guidelines for it, because, moreover, what they say is that in nursing matters, it clearly talks about nursing care. So what it says, which went quite far in its statement, I don't know if I have it there, but what it says is that the one who watches over the diseases of and the care, sorry, the diseases, the pathologies, and the prevention of patients is always the doctor, something like that, I don't know if exactly like that, but very similar. And it says that while the nurse must limit themselves to nursing care in accordance with the LOPS, they also based themselves on Royal Legislative Decree 1977 of 2003, because, well, there is a clear care unit, which is the U-48, which clearly tells us that aesthetic medicine is done by a doctor. And then there is another thing. They have included NANDA, NIC, I don't know if you are familiar with these terms, which in reality they have made themselves, because these are terms from an American nursing association that have been gradually introduced. And the NANDAs are the nursing diagnosis. Then there are the NOCs, which I think is like the possibility of a solution, and the NICs, which are the responses. So, for example, in the lawsuit, I provided this information, saying, "Look, I don't give it the veracity that a norm might have, for example, because in the end it is drafted by a simple scientific society." But the truth is that when we break it down, and this is how most health departments do it, what a patient has, what can be diagnosed with it, the nursing diagnosis. The nurse, for example, has a wound. So what they can do is the diagnosis, the prescription, the treatment that can be done is purely nursing care. So, yes, there have been certain guidelines. And then it is true that there are certain regulations, for example, even if they are minor, we have the circular on botulinum toxin. We also have a resolution on PRP from the Medicines Agency. I mean, we put absolutely everything in. But what was absolutely clear, clear, clear to Ivo, is that the directive on training, the European directive. But what they were clear about is that the LOPS gave them the guidelines for these, at least that's what they based themselves on, and I think with good judgment. But it is true that the terms are always very much about nursing prescription, and so on. And when they tell you that, it's that I don't do aesthetic medicine. Of course, they went from doing aesthetic medicine courses for nurses, which still exist, to doing corpoesthetic dermoesthetic nursing courses, where they say, "I don't do it." And dentists say, "I don't do it." They say, "I don't do aesthetic medicine." Of course, you are doing the same treatments. But well, the Superior Court of Justice, that's why I tell you, it's not an intrusion lawsuit. I find it a bit difficult to tell those who are not lawyers that we are not in the criminal sphere, so that they go to jail. We are not in the administrative sphere. What it says is that the college cannot do these things. But the truth is that it goes a little further, and they do define what things they consider a doctor can do, and to date, it has been the TSJ of Madrid, with four or five sentences, and subsequently, it has also been the Supreme Court, and it seems to have it clear, simply with this type, I think it's also a matter of common sense, and then the controversy ends. That is, when you talk about the spirit of the law or the regulation, what is behind it? Because easily, you put, well, there are certain economic interests, no doubt. But what also happens is that European regulations, despite Brexit, until now we have had the United Kingdom, the diseases of the United Kingdom. Of course, they inject, and in some Nordic countries too, they have more extensive faculties than, for example, they have in Spain. That's why the caveat is that it will depend on national legislation. So, of course, it all comes from there, and it all comes from lobbies. Europe lives on lobbies. So, of course, and also, as I was saying, nurses are many and they are very united, as are beauticians. We also did the C403 and 409. It's a voluntary regulation. First it was for aesthetic surgery, then it was split into surgery and aesthetic medicine. But then the 409 appears, which is for beauty centers, and one of our doctors goes and they tell her to leave, they expel her from Aenor, from Une, not Aenor, who are charming, but the beauticians who are there. And she says, "But this norm, you are introducing mesotherapy." So, okay, beauty centers, but you are introducing, and there has been a confrontation. We from SEME have filed an appeal in Europe, doctors from all over Europe saying, "No way," and so on, and we managed to get it out. But they were introducing mesotherapy, radiofrequency, absolutely everything. So, of course, everything moves by lobbies. But also in the matter of nurses, it's that there are certain, well, but now we have them out, those from the United Kingdom, but they have a lot of strength. Yes, some other Nordic country, I don't know if it's Finland or Norway, some, you can, yes, I knew it was some, I knew there was some Nordic country with that. I think what they have done is to solve it by saying, depending on, because in health matters, it is true that each country is sovereign. So they have done it this way. What happens is that the nurses forget the last part of the phrase. I don't know if, well, no, no, it wasn't a question, it was a reflection. In fact, I congratulate you on your presentation, and on the topic of social networks, I think there is a keyword for doctors on social networks, and that is "hesitate." That is, from the outset, when they ask you, from the outset it has to be a "no," and then we will analyze what you want to do on social networks, because there are many doctors who are quick on the trigger, who do it first and then consult you. So, from the outset, don't do it. First, get advice. First, say "no," and then we'll do the X-ray of what you want to do. It's a bit, moreover, it's a very good conclusion, and that has shown why sanctions are starting to arrive, because because we have gone too far, it is very clear that it is because we have gone too far. And then because of the trivialization, for example, in aesthetics, because we have gone too far, because it is normal, all of this. If you go too far, in the end, you are a doctor and you must not forget that you almost, almost have to go by word of mouth with those patients who come because you work well. It is true that social networks must be used as something today, as a very useful method for them, to build your brand, to expose yourself a bit, to say, "Hey, I'm here," not like before, when they had to reach your door by all means. Well, today, it facilitates that, but let's be very cautious, because in the end, we are doctors, and also, I don't know, I personally, I don't feel like going to, I don't know, a doctor who is, I was going to say an example, but everyone will know who I'm talking about, and it's not worth it. But I mean, that it's very trivial, it's vulgarizing, and what I want is to go to a real doctor and be treated well, and not to appear, well, with pins. I think that term has been one of the worst, I think it has done us more harm than intrusion. But well, yes, totally agree with that, with the fact that we have to be very careful and that doctors are responsible for it. How are you? Good morning. Congratulations on the presentation. I really know you are a specialist because you have it perfectly memorized, including the regulation numbers and everything. And you have explained to us in the part about social networks and advertising what we cannot do. You have shown us a manual of good practices, which is very well known because it is also worked on by the marketing department, but from the college, from the collegiate section, from SEME. They don't tell us, I think they tell us what we cannot do, but could there be a way to say, "Look, this can be done," and with some practical examples? Because they really tell us, "You can't do that." But I explained a treatment I performed. Do I comply or not? If I say the name of the drug, or if I say the name of the laboratory, do I comply? What specifically can be done, and what cannot? Because the regulation is very specific, but to go into detail about what could be done. Well, in legal matters, as you know, what is not prohibited is, in a way, permitted. That's what we wanted to show. Well, yes, for example, as I was telling you, hyaluronic acid, all medical devices, here in Galicia, they can be used as long as we don't use the brand. That is, I can say that I do threads, but I cannot say that I use Yvo-derm, no, sorry, hyaluronic acid. I cannot say that I use Yvo-derm. Photos, well, with the patient's authorization, of course, trying not to identify them. That is, if I am going to do a cellulite treatment, I will avoid their face and so on appearing. Those before and after photos, let's do them with caution, perhaps more as a part of information than as a part of advertising. Well, a bit to comply with all those criteria. But I don't know, but well, I can propose that SEME, all of a sudden, say, "From now on, we will send positive messages." This is what can be done. But well, it's a bit like that. What cannot be done is very clear, it is very clearly marked and defined, especially for medications. The rest is a bit more diffuse, and moreover, we run the risk if we say before and after photos. Yes, before and after photos can be taken, but then the college appears and says, "Dental commission, no, no, no, because you are using photographs with an advertising intent." So, well, sometimes it's better not to say it so explicitly and play a bit with ambiguity. We find ourselves in an environment where something I don't do, I'm more careful, I'm less careful. Nothing more. It's very hard, because I understand that there are people who are suffering because they see that they cannot advertise, and that their neighbor advertises everything. But this, this happens like with the toxin. What measure do they say? To everyone. Why do you tell me it's only this area? If my neighbor injects here, here, here, here, here, here? Well, that's each person's risk. I mean, what we have to tell you, what we as a scientific society have to tell you, and the college as a college, which is, has to say what is right. From then on, the risk is personal. The assumption of risk is personal. We have to say, this can be done, this cannot be done. From then on, each person takes their path, their decision, because a 90,000 euro sanction doesn't cost the same to one as to another. So we also know that that marks a bit of a difference. Thank you very much, Rosa. I wanted to ask you about the WHO with dentistry. How is that? Well, it seems there has been a ratification just two weeks ago, because it is true that there have been many criticisms from many places. Castilla y León was quite furious, Catalonia, I think, too. There are several autonomous communities that were, autonomous community colleges, annoyed. But what they have ratified is the same. Let's see, because dentists are a different matter from nursing, among other things, because dentists are prescribers, which nurses are not. No doubt there is a big difference. Then they have their law, I think it's 1086, maybe Law 1086, I think it is. So there is already a matter of criteria about what is medicine and what is dentistry. It is clear that they are two different careers and two different functions. So I understand that they can do everything that is for oral health, and I understand that it should be interpreted that way. It seems that in that, they have not interpreted it that way. What has been criticized a bit by SEME is not so much the legal criterion, which I insist, the dentist has their law 1086, which is a prescriber, which has a series of things. What has been criticized most by SEME is with what purpose has that letter been issued by the WHO? I mean, why? Because in the end, you are with your doctors. Well, support them when they have won a lawsuit, even you, WHO, in the Supreme Court and so on, issue news about it, try to fight against intrusion that affects aesthetic medicine or medicine in general, because this is not aesthetic medicine, this is medicine. So, it was not well understood, and it is a bit what was transmitted by SEME, why issue that statement? Apart from the fact that we did not agree with some of the statements made, there were rats, for example, it talked about medication when it was talking about threads or things like that. But those can be minor issues. But well, what was finally said is, well, we understand that this is why it talks about toxin. Are you telling me in the title that a treatment is being carried out, a statement is being made to fight against intrusion in general and facial in particular? So why do you talk about the toxin if you are only going to use it in the lower third? You are not going to touch this area. Why do you include it? I mean, it gives the impression that it goes further. Another thing is that they can use it for bruxism, through the special law, for special use, sorry, for a play, things like that. But why include it if you are making a statement about aesthetics and you are in this area? Why do you include it? I mean, in the end, what bothered SEME is that we doctors are very separated, very distant from each other, and we see that dentists go hand in hand. We see that nurses, their president says, "I don't care about the sentences, I'm with my people." And suddenly, we, being doctors, our college says that dentists can do a series of things, some of which we understand as more or less doubtful, or at least the way it was drafted. But well, from the outset, a second statement has been made in the same terms, and well, that's a bit what it is. For us, it's more the bad taste of having issued the statement than more than anything else, because it is true that there is a big difference between dentists and nurses, there is no doubt about that. I think the statement was unfortunate. The statement was unfortunate, but again, the spirit of the statement, I don't think it was intended to cause any controversy. I was at the WHO meeting where this topic was discussed, and I was able to hear the president argue the same thing. The statement was precisely intended to mark a distance between dentists and doctors, and other health professionals. Then, it is true that the statement is not fortunate in some affirmations, and then it does not count with SEME when it is made, which assumes this responsibility, and what is said in that, in that.
That assembly is that a second statement is going to be made, trying to get a contribution and one from SEME. I don't know how it ends. They know that SEME was against it because there was a first prior meeting when the previous president was there, Dr. Cobo was not there, the previous one was there, the same lawyer was there, and there was already an online one because it was a bit of the COVID era, and it was already seen there that there was a certain friction. I mean, there was a debate and friction was known a year before, and it's true that we didn't participate then. Then it's true, yes, it's true that when we later sent a letter, we complained, and especially when many colleges complained, they called us and told us, "Come here." I thought they were going to be quite generous with the nursing issue. I said, "Well, they've done damage there because they've done damage." We don't agree with their criteria because for us, one thing is oral health, which yes, can be parked, and their law says so, different areas: lips, mouth, meaning not just teeth, but oral health. But I said, "Well, at least they could throw us a bone with nursing," and the response was that they were sorry, that this sentence is not yet final, and that anyway, they made a statement at the time when there was a Supreme Court ruling, which they already put on their website. So, I mean, there hasn't been any support either, because maybe it could have been a great help. Well, the statement was a bit clumsy, or we didn't understand why it was released, because only the College of Dentists could have released that statement. There was no need for the OMC to endorse it, I understand. But well, that's an absolutely subjective opinion, but what we don't understand is why the OMC gets involved there. However, we asked them to make a strong statement about nursing, that the entire regulation... it's not that it's something... I tell you, I'm going to sue a nurse in Cádiz because he's taking years off my life, I mean, I'm telling you, and nothing is being done. I mean, we have this gentleman recorded saying that doctors will die, that patients will die looking doctors in the eye because the nurse knows where to inject, but I have it recorded on my WhatsApp, like this, but they will die like this, touching themselves and looking each other in the eye, unless they are lucky enough to get an anesthesiologist who knows how to inject a bit, you know. All these things I take, I transcribe them so that they don't have them and I send them, and no action has been taken. And of course, then you see, I am envious. I'm not going to change anything. I'm going to be a lawyer for nurses because, of course, I have their president who says, "I don't care about a Supreme Court ruling, and I'm with my people to the death." So, well, this is very politically incorrect. I hope no one is recording and that this part is no longer here, but well, I think there should be a little more support among all doctors and the OMC, of course, which is the home of all doctors. So, but well, legally I don't get involved because it's true that I perceive, and I have conveyed this to SEME and others, to any of the doctors I have spoken with, be careful, it has nothing to do with a dentist or a nurse, absolutely nothing to do with it. They have their law 1086, they are not limited to the mouth because, moreover, their law, and it's from '86, I insist, talks about the mouth, the lips, adjacent areas, and so on. And well, all that is clear. What happens is that another question is then, in what is the medical profession or aesthetic medicine, aesthetic dentistry? There are things that yes, clearly, teeth whitening is there. There are many things that differentiate them, but putting on a lip or removing all these wrinkles... well, I don't know, I don't know. That would have to be evaluated, and I don't doubt the dentistry studies and how they can be very well informed in all that is anatomy of this whole area. But well, I think the statement was an excess and I see it as unnecessary. It has created a crisis that perhaps was not necessary, but well, I insist, it is a personal opinion, and moreover, I am not speaking even by name, neither of SEME, nor of the college section, nor of anything. I speak in my own name because I have learned of these statements firsthand. Well, the issue was difficult, but moreover, the last question, maybe they won't let me into any medical college from now on. This part, I'm going to tell the colleagues here to cut it. I don't know if you want to comment on anything else. Then that's it. I think everything has been very clear. Very good for the presentation, and I think I have to thank you because, as always, spectacular. Thank you. Thank you to you. Thank you. [Music] [Music]