The advertising rules for GPs offering skin cancer checks

Most GP practices that offer skin cancer checks treat their marketing as low risk. There are no injectables, no cosmetic claims, no before and after photos. Just a service page, a Google Business Profile and a Facebook page that mentions skin checks a few times a year.

The advertising law does not make that distinction. Section 133 of the Health Practitioner Regulation National Law applies to all advertising of a regulated health service, and general practice is as regulated as any cosmetic clinic. The five prohibitions are covered clause by clause in the AHPRA guidelines article. This page applies them to the specific ways GP practices advertise skin checks, and to the specific traps I see when I review practice websites. It is general information, not legal advice about your practice.

The five prohibitions, in general practice terms

Section 133 says advertising for a regulated health service must not do five things: be false, misleading or deceptive, offer a gift or discount without stating the full terms and conditions, use testimonials, create an unreasonable expectation of beneficial treatment, or encourage indiscriminate or unnecessary use of health services.

For a practice advertising skin checks, the traps cluster in four places: how the doctor’s experience is described, how offers are worded, how reviews are handled, and how the practice encourages people to come back. Each one gets its own section below. Breaching section 133 is a criminal offence, and every non compliant piece of advertising counts as a separate offence, so a wording problem repeated across your website, your Google profile and your Facebook page is not one problem.

The specialist trap

This is the breach I find most often on GP websites, and it is usually written in good faith.

A GP who has done thousands of skin checks, holds extra qualifications in skin cancer medicine and spends most of the week on dermoscopy is, in plain English, someone who specialises in skin cancer. In advertising law, that word is not available. Specialist, specialises in, specialty and specialised all require actual AHPRA specialist registration in a recognised specialty. A GP without specialist registration in that field cannot use them, however deep the experience runs.

The compliant alternatives do the same job: substantial experience in skin cancer medicine, or working primarily in skin cancer detection. Qualifications and experience can be stated accurately and factually, so a postgraduate certificate, years in practice and the volume of the work can all appear on the page. Acronyms for professional memberships need to be spelled out rather than left as letters after a name.

The misleading advertising prohibition backs this up from the other side: claiming a practitioner holds specialist registration, qualifications or endorsement they do not hold is expressly listed as misleading. Restricted titles carry their own separate offences, which is the territory covered in the cosmetic surgeon title article.

One piece of good news. The title Dr is fine for medical practitioners as it stands. The requirement to state a profession alongside the title applies to practitioners who are not medical practitioners, so your GPs can be Dr on every page without a qualifier.

Your Google profile and Facebook page are advertising

The guidelines treat all of the following as advertising: your website, your social media accounts, paid ads, printed material, signage, directory listings and your Google Business Profile. A GBP post announcing skin check availability, and a Facebook post reminding followers that summer is coming, sit under section 133 exactly as your website does.

In practice, these are the channels where breaches happen, because they are written quickly and reviewed by nobody. The website got a careful once over three years ago. The Facebook page gets a post written in five minutes on a Tuesday. Both are advertising, and the quick one is where the urgency wording and the casual offer tend to slip through.

Free spot checks and the terms and conditions rule

Offers are allowed. A free or discounted spot check is not a breach in itself. The breach is offering a gift, discount or inducement without stating the full terms and conditions in the advertising itself.

The classic failures apply directly to spot check promotions: a free check where the cost is recovered in a billed follow up consultation, an offer with hidden restrictions on age, expiry, geography or eligibility, and terms that exist somewhere but take exhaustive searching to find. If the free check is one lesion only, for new patients only, until the end of March only, all of that belongs in the ad, not behind a link or in the fine print at reception.

Recalls and reminders versus encouraging unnecessary use

The fifth prohibition bans advertising that encourages indiscriminate or unnecessary use of health services, and the guidelines list encouraging periodic or regular appointments without clinical indication as a breach. That sits uncomfortably close to how skin check marketing is usually written, so the line matters.

On the safe side: recalls and reminders tied to an individual patient’s clinical need. Advertising is promotion of a health service to the public, and information provided to patients about their own condition is not advertising. A recall to a patient whose history calls for annual review is patient care.

On the wrong side: promotion to the general public urging everyone to book regular skin checks regardless of clinical need, and urgency wording attached to health claims. Phrases like do not delay, act now before it is too late and for a limited time only are expressly flagged in the guidelines when linked to unsubstantiated health claims. Skin cancer marketing leans on urgency more than any other general practice service, which is exactly why this prohibition catches it.

The practical rewrite: describe the service, state who skin checks are clinically relevant for in factual terms, and let the patient and their GP decide frequency. Keep the urgency out of the public facing copy and the clinical judgement in the consultation room.

Reviews on your website versus reviews on Google

Testimonials in health service advertising are banned outright. A testimonial is any positive statement about the clinical side of the service: the symptom, the treatment, or the outcome, including praise of the practitioner’s skill. The full scope is covered in the testimonial rule article.

For a GP practice the distinction that matters is where the review lives. Reviews sitting on Google, on a third party site you do not control, are not your advertising. Embed those same reviews on your practice website through a review widget and you have turned someone else’s words into your testimonial, in your advertising, under your control. The same shift happens on the third party site itself if you engage: liking, responding to or resharing a clinical review can constitute using a testimonial in advertising.

Comments purely about customer service or communication style, with no clinical reference, are not testimonials. In practice, review widgets do not filter for that distinction, which is why I flag every embedded review widget I find on a practice site.

A note on the TGA

The TGA’s rules on advertising prescription medicines are usually irrelevant to this segment, but they arrive in full the moment a practice adds cosmetic services involving prescription only medicines, and they are covered in the TGA advertising code article.

Check where your practice stands

Practice managers usually inherit the website, the Google profile and the Facebook page from whoever set them up, with no record of whether any of it was checked against the National Law. If that is your situation, the practice manager compliance guide is the starting point, and the free compliance audit checks your website, Google Business Profile and social pages against the current guidelines, with every finding in writing and the clause it sits under. No call required.