Yes — a clinic can outsource the production of its social media content, but not the legal responsibility for it. Under the Healthcare Services Act 2020, only the licensee or a person acting on the licensee's authority may advertise a licensable healthcare service, and that duty cannot be handed to a supplier. A supplier can plan and produce the content; the clinic stays the advertiser of record and a qualified person signs off before anything is published.
The distinction that matters is between producing the advertising and being responsible for it. You can hand production to a supplier. You cannot hand over the licensee's compliance duty — the law keeps that with the clinic.
| Can be outsourced | Stays with the clinic |
|---|---|
| Planning the content calendar | Being the advertiser of record |
| Writing captions and producing visuals | Final approval / sign-off by a qualified person |
| Applying the clinic's rules as content is made | The non-delegable duty to keep advertising compliant |
| Delivering the finished month for review | Publishing to the clinic's own accounts |
Under section 31 of the Healthcare Services Act, only the licensee or someone acting on the licensee's authority may advertise a licensable healthcare service, and the licensee's duty to keep that advertising compliant is non-delegable. Aesthetic procedures by licensed providers are medical procedures under the Act, and advertising them is regulated under the Healthcare Services (Advertisement) Regulations 2021. In practice this means a supplier can build the content, but the clinic must stay the advertiser and a qualified person must approve each post before it is published.
The workable pattern is to set the rules up front and apply them as the content is created, not to check them at the end:
Pulse Managed is a done-for-you service built around exactly this arrangement: we plan and produce the clinic's month with your compliance rules applied as we generate, you stay the advertiser of record, and your qualified person signs off before anything is published. We don't auto-post and we don't take your logins. If you'd rather run it yourself, the same engine is available as self-serve software from US$99 per month.
Yes, a clinic can outsource the production of its social media content, but it cannot outsource legal responsibility for that advertising. Under the Healthcare Services Act 2020, advertising a licensable healthcare service is regulated, and only the licensee or a person acting on the licensee's authority may advertise it. The clinic stays the advertiser of record, and its duty to keep advertising compliant cannot be handed to a supplier. A supplier can plan and produce the content; a qualified person at the clinic should review and sign off before anything is published. This is general information, not legal advice.
The licensee. Under section 31 of the Healthcare Services Act, only the licensee or someone acting on the licensee's authority may advertise a licensable healthcare service, and the licensee's duty to keep that advertising compliant is non-delegable. A content supplier can produce the posts, but the clinic remains the advertiser of record and a qualified person should approve every post before it goes out.
Aesthetic procedures performed by licensed providers are medical procedures under the Healthcare Services Act 2020, and advertising them is regulated under the Healthcare Services (Advertisement) Regulations 2021. Clinics should also work within the relevant MOH, HSA, SMC and SMA guidance. A non-medical supplier may not advertise a licensable healthcare service on its own account, which is why the clinic must stay the advertiser and sign off on content.
Set the clinic's rules up front and apply them as content is created, rather than checking at the end. A workable arrangement is: the clinic defines what can and cannot be said; the supplier builds those constraints into every caption and visual as it generates them; a qualified person at the clinic reviews and approves each post; and the clinic publishes it. Nothing is auto-posted, and the supplier does not take the clinic's account logins. Confirm the arrangement with your own adviser before starting.
Yes. Pulse Managed is a done-for-you service that plans and produces a clinic's month of content with the clinic's compliance rules applied as the content is generated. The clinic stays the advertiser of record, a qualified person signs off before anything is published, and Pulse does not auto-post or take logins. It reduces risk and saves time, but it is not legal advice and does not replace professional review or guarantee compliance.