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Brexit Frequently Asked Questions

How Brexit may affect Vitality, your plan or your contract with us

We’re committed to providing you with a seamless service and have taken reasonable steps to prepare for the UK’s withdrawal from the European Union (EU). Whether you’re a member, broker, adviser, introducer or have a contract with us, we’ve answered your most commonly asked questions about the UK’s withdrawal from the EU and how it may affect Vitality, your plan or your contract with us. 

How will Brexit affect VitalityHealth and my health plan?

VitalityHealth is a UK regulated firm offering Personal, Business and Corporate healthcare plans to UK residents and businesses. VitalityHealth’s product and coverage is unaffected, regardless of when, or how the UK leaves the EU.

Note to Republic of Ireland (RoI) members:

The UK’s withdrawal from the EU will result in the loss of passporting for UK firms doing business in the European Economic Area (EEA). VitalityHealth does “passport” into the RoI in order to provide cover to a number of RoI residents who are members of Northern Irish Business and Corporate schemes. 

In the event of the UK’s withdrawal from the EU without a deal, or a withdrawal agreement that does not include financial services, VitalityHealth will lose its passport into the RoI. If you are a RoI member please rest assured, VitalityHealth will continue to cover you as we will make use of Part 8 of the Withdrawal of the United Kingdom from the European Union (Consequently Provision) Act 2019 by informing the Central Bank of Ireland of our intention within three months of the UK’s exit from the EU, to do so. This will allow VitalityHealth to continue servicing RoI members until your UK employer’s scheme is up for renewal. At the point of renewal, your employer can select which product best suits their needs in the post withdrawal environment. This approach will ensure service continuity in the event of the UK’s withdrawal from the EU on a no-deal basis.
 

How will Brexit affect my Worldwide Travel Insurance plan and travelling to the EU?

Our travel insurance product is unaffected, regardless of when, or how the UK leaves the EU. Your right to travel to EU countries will also be unaffected by Brexit and you will not require a visa. Please be aware that it’s possible there will be some short-term disruption to travel, especially if the UK leaves the EU without an agreement. Therefore, if you’re travelling around the time the UK is due to leave, you should allow additional time for travel and check the latest travel information online.

The European Health Insurance Card (EHIC)

This is an arrangement between EEA countries (and Switzerland) for citizens of one EEA country to receive basic healthcare in another EEA country, as if they were a resident of that country. In the event that the UK leaves the EU without an agreement, the EHIC may not be accepted by other EEA countries for UK citizens. For more information about the EHIC, please visit the UK Government website or NHS website.

Our Worldwide Travel Insurance Plan gives you comprehensive cover for emergency medical expenses, but some routine – non-urgent – treatment that may have been covered by EHIC will not be covered under the plan.
 

How will Brexit affect VitalityLife and my life insurance plan?

VitalityLife is a UK regulated firm offering pure protection products to UK residents only. VitalityLife’s products do not place geographical restrictions on members once a policy has been sold and will be unaffected, regardless of when, or how the UK leaves the EU. 

If a member subsequently emigrates to the EU post conclusion of their life insurance contract the policy will still be in force. VitalityLife does not need to seek EEA authorisation in order to service these contracts in future, for example in the event of a claim. This is based on the guidance regarding life insurance issued by the European Insurance and Occupational Pension Authority (EIOPA):

“If a policyholder with habitual residence in the United Kingdom concluded a life insurance contract with a UK insurance undertaking and afterwards the policyholder changed its habitual residence… to a EU 27 Member State, the NCAs [National Competent Authority] should take into account the supervisory review that the insurance contract was concluded in the United Kingdom and the UK insurance undertaking did not provide cross-border services for the EU 27 for this contract.”
 

How will Brexit affect VitalityInvest and my ISA or Pension plan?

VitalityInvest, which is a trading name of VitalityLife, a UK regulated firm, offers Pension and ISA products to UK residents only. The products do not place a geographical restriction on members once a plan has been sold and will be unaffected, regardless of when, or how the UK leaves the EU. 

The Pension and ISA products are ‘life policies’, so if a member subsequently emigrates to the EU post conclusion of their life insurance contract the plan will still be in force. VitalityInvest does not need to seek EEA authorisation in order to service these contracts in future, for example in the event of drawing an income. This is based on the guidance regarding life insurance issued by the European Insurance and Occupational Pension Authority (EIOPA):

“If a policyholder with habitual residence in the United Kingdom concluded a life insurance contract with a UK insurance undertaking and afterwards the policyholder changed its habitual residence… to a EU 27 Member State, the NCAs [National Competent Authority] should take into account the supervisory review that the insurance contract was concluded in the United Kingdom and the UK insurance undertaking did not provide cross-border services for the EU27 for this contract.”
 

Will the UK’s withdrawal from the EU affect Vitality’s approach to our intermediaries and introducers

No. The UK’s withdrawal will not affect our approach to our intermediaries or introducers. We require that all intermediaries and introducers agree terms of business prior to conducting any business with us. And we require that intermediaries are authorised in the UK and hold the correct permissions to conduct the business being proposed – the UK’s withdrawal from the EU will not affect these requirements.
 

How will Brexit affect Vitality’s outsourced providers?

We’ve liaised with our EEA-based suppliers, all of whom have assured us that leaving the EU without a deal will not affect their ability to continue to provide services to Vitality on a seamless basis.
 

Will the UK’s withdrawal from the EU affect the legal contracts that Vitality has entered into?

No. Our contracts state that we comply with ‘applicable law’, which makes Vitality’s contracts automatically reactive to any legislative changes. For example, if there were a European Regulation or Directive that is no longer applicable post leaving the EU that law would no longer apply to our contracts.
 

Where does Vitality store my data?

Vitality uses server facilities within the UK, EEA (Germany and Ireland), and South Africa. This does not include our third parties who are listed in our Privacy Notices:

What preparations has Vitality made for data storage in the event of the UK’s withdrawal from the EU without a deal?

Where data is stored in the EEA this will continue to be permitted as the UK Government says that the UK intends to deem the EEA “adequate” for data transfers in the event that the UK withdraws from the EU without a deal. However, transfers from the EU to UK will need a data export solution or derogation unless/until the UK is deemed adequate to receive EU Data.

Does Vitality share my data with European Economic Area based companies and if so, what protocols are in place to ensure my privacy? 

The UK Government says that the UK intends to deem the EEA as adequate for data transfers. In addition, for the time being reliance on EU Standard Contractual Clauses will be permitted for UK transfers, outside the EEA. A later proposal will have the Secretary of State approve “standard data protection clauses” UK transfers under EU-US Privacy Shield, subject to Privacy Shield recipients publically declaring that their Privacy Shield commitments will apply to UK exported data in accordance with International Trade administration guidelines. The UK will also permit transfers to all countries currently recognised as “adequate” by the EU.