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Legal and

VitalityHealth is a trading name of Vitality Health Limited and Vitality Corporate Services Limited. Registered numbers 05051253 and 05933141 respectively. VitalityLife is a trading name of Vitality Corporate Services Limited and Vitality Life Limited registered number 03319079.

Vitality Life Limited is the insurer which underwrites the VitalityLife plan. Vitality Health Limited is the insurer which underwrites the VitalityHealth plan, Vitality Corporate Services Limited arranges and administers the VitalityHealth and VitalityLife plans. All companies are registered in England and Wales.  Registered offices at 3 More London Riverside, London, SE1 2AQ.

Vitality Corporate Services Limited is authorised and regulated by the Financial Conduct Authority.

Vitality Health Limited and Vitality Life Limited are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Trust administration business is handled by Vitality Corporate Services Limited and this activity is not regulated by the Financial Conduct Authority.

Calls may be recorded/monitored to help improve customer service. Call charges may vary.

Legal information Data protection

Privacy policy

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Vitality Corporate Services Limited (trading as VitalityHealth and VitalityLife) of 3 More London Riverside, London SE1 2AQ.

VitalityHealth and VitalityLife (“the Vitality Group”, “we”, “us” or “our”) are health and life insurers that offer their members a range of incentives and benefits for being healthy. This privacy policy applies to our non-investment private medical insurance plans, life insurance and protection plans, our range of incentives and benefits, our website located at (“our site”) and our Vitality mobile applications for iPhone OS and Android OS (collectively referred to in this privacy policy as the “Services”). 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  By using the Services you are accepting and consenting to the practices described in this privacy policy.

What type of data will be collected?

We may collect and process the following data about you:

(i) Information you give us 

You may give us information about you when you use the Services, by filling in forms on our site or by corresponding with us by phone, email, post or otherwise.  This includes information you provide when you register to use the Vitality Member Zone, enter into a competition, promotion or survey and when you report a problem with our site.  We may also need to collect sensitive personal data which could include details around your physical and mental health. You can choose whether to supply or withhold any sensitive personal data.  However, withholding this information may restrict the Services we are able to offer you.

(ii) Information we receive from other sources

We may receive information about you from third parties who assist in the provision of the Services (including but not limited to, service providers and prospective new Vitality partners, sub-contractors in technical payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies).  We will always ensure that any data we receive has been collected lawfully and fairly in accordance with your rights under the Act.

How we use your personal data

We will only collect personal data which is necessary to provide you with the Services or an associated or required service. We may process your personal data and sensitive personal data for the following reasons:

  • administration and management of our Services;
  • as part of our business processes and relevant activities including auditing, business planning, accounting and transactions;
  • compliance with legal and regulatory obligations;
  • for research, statistical purposes or to improve our Services, including developing new wellness or reward partnerships;
  • to generate and administer the weekly or monthly rewards earned as a result of you getting active in accordance with the Services;
  • to award Vitality points;
  • to notify you about changes to our Services;
  • to improve our site to ensure content is presented in the most effective manner for your computer;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you; and
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

This is not an exhaustive list and is subject to change where business, legal or regulatory requirements may dictate. We may combine information received from other sources with information we collect about you for the purposes set out above.

Processing claims

In the event of a claim, we may have to give some information to those involved in your treatment or care and/or your representative (if you have chosen one). This will be done confidentially.

An insured dependant aged 16 or over has the right to confidentiality in relation to their claims and information. In order for them to exercise this right the insured dependant should contact customer services.

If you have another insurance plan that covers the same costs that you are claiming from us, then we may also disclose your relevant personal information to that other insurer so that we can ensure we only pay our proportion of the claim.

How we may keep, store and dispose of data

We hold data in various forms including electronic databases, computerised files and paper files. Data will be held for a reasonable period of time, which may include a period of time after a plan ends. Data will be disposed of in line with approved company processes to ensure all reasonable efforts and precautions are taken to protect the confidentiality of the data. We may continue to keep non-personally identifiable data for the research and statistical purposes to improve our Services.

Who we may share data with

We may disclose data to selected third parties for the purpose of administering the services, including the following:

  • service providers;
  • sub-contractors in technical payment and delivery services;
  • analytics providers and search information providers;
  • credit reference agencies for the purposes of assessing your credit score where this is a condition of us entering into a contract with you; and
  • any legal or regulatory organisation provided that we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • If you have appointed an insurance adviser we will send them copies of correspondence relating to the plan and any renewal documentation. We may disclose information about a claim to them, although no medical information will be provided without your consent. Your information, and that of others also covered by the plan, may be disclosed to other parties (for example other insurance companies) with a view to preventing fraudulent or improper claims.

In order to help you maximise the benefits of Vitality, we will disclose limited data to:

  • brokers regarding your engagement with the Services, as they are well-placed to promote the benefits of the Services and ensure you receive the most from your plan;
  • prospective new Vitality partners in order for us to develop and improve the Services; and
  • where your insurance is paid for by an employer, we may provide non-personally identifiable data to the employer to allow them to assess the impact of Vitality on their workforce.
  • In all cases we adopt privacy enhancing technologies as promoted by the ICO and in accordance with EU guidance.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of the Services, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.


You have the right to ask us not to process your personal data for marketing purposes. We will always inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by logging into the Member Zone and sending us a secure message, by contacting our customer services department or by sending us an email at

Your rights to request, review and amend personal data

You have the right to request a copy of the data we hold about you and to have any inaccurate data corrected. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.  If you wish to request this data, please contact the Subject Access Request team:

Post: DSAR Team, St Christopher House, 217 Wellington Road South, Stockport SK2 6NG

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or post. Please check back frequently to see any updates or changes to our privacy policy.
Site security

Site security

Vitality take information security very seriously and take all reasonable steps to secure and protect your information. We have an effective encryption system in place to protect any electronic communications to our website. We also have secure firewall software and other measures in place to prevent unauthorised access. Look for a padlock symbol next to the address bar to confirm that you are in a secure area.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

When you send information to us by email, please bear in mind that the transmission of information over the internet is not completely secure, unless the information is encrypted. Whilst we take all reasonable steps to protect your personal data on our systems, we cannot guarantee the security of any data you choose to email to us, so, please be aware that sending us your personal data via email is at your own risk. Once we have received your information, we will use strict procedures and security controls to ensure its ongoing confidentiality and protection.

With regards to each of your visits to our site we may automatically collect the following:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); plans you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service number.

If you have any concerns in relation to the security of our site or your personal data contained within it, please contact the Subject Access Request team:

Post: DSAR Team, St Christopher House, 217 Wellington Road South, Stockport, SK2 6NG.

Telephone calls

Telephone calls

Calls may be monitored and recorded for training and compliance purposes.

Call charges may vary.

Unless indicated lines are open Monday to Thursday, 8.30am to 6.00pm and Friday, 8:30am - 5:00pm.

If you call VitalityLife, you may be speaking with a financial adviser from Genesis Financial Advisory Services (UK) Ltd (Financial Conduct Authority Firm reference number: 518666). Genesis is directly authorised to support VitalityLife Advisers outside our standard operating hours and when we experience higher than normal customer enquiries.
Solvency and Financial Condition Report

Solvency and Financial Condition Report

Under the Prudential Regulation Authority (PRA) rules and Solvency II regulations, a PRA-authorised insurance undertaking (firm) must disclose publicly, on an annual basis, a Solvency and Financial Condition Report (SFCR). The SFCR contains narrative information in quantitative and qualitative form supplemented, where appropriate, with quantitative templates. A firm’s SFCR must contain the following information:

1. a description of the business and performance of the firm;
2. a description of the system of governance of the firm and an assessment of its adequacy for the risk profile of the firm;
3. a description of the risk exposure, risk concentration, risk mitigation and risk sensitivity separately for each category of risk of the firm;
4. a description, separately for assets, technical provisions and other liabilities, of the bases and methods used for their valuation, together with an explanation of any major differences in the bases and methods used for the valuation of those assets, technical provisions and other liabilities in financial statements of the firm; and
5. a description of the capital management of the firm, including information on own funds, solvency capital requirement and minimum capital requirement.

The Group have prepared three individual or solo SFCRs for Vitality Life Limited, Vitality Health Insurance Limited and Vitality Health Limited and an EEA Group SFCR for Discovery Group Europe Limited.


Vitality Life Limited SFCR for the year ending 30 June 2017

Vitality Health Insurance Limited SFCR for the year ending 30 June 2017

Vitality Health Limited SFCR for the year ending 30 June 2017


Vitality Life Limited SFCR for the year ending 30 June 2016

Vitality Health Insurance Limited SFCR for the year ending 30 June 2016

Vitality Health Limited SFCR for the year ending 30 June 2016

Discovery Group Europe Limited SFCR for the year ending 30 June 2016
Modern Slavery Act 2015

Statement by Neville Koopowitz, CEO for Vitality Health and Herschel Mayers, CEO for Vitality Life

Vitality seeks to eliminate human trafficking and slavery from our supply chains.  We strongly oppose any use of slavery or human trafficking in the provision of
our services and promotes ethical and lawful business practices within our workplace.  Vitality will not tolerate or condone any form of policy or practice that constitutes human trafficking or slavery in any part of our organisation.  This policy complies with the UK Modern Slavery Act 2015.
Vitality suppliers are an important part of our success and our culture.  We expect each business partner to conduct their business with the same commitment to ethical business practices as Vitality.  This includes:

  • Suppliers are not to use slave labour, illegal child labour or forced labour
  • Suppliers will ensure that the overall terms of employment are voluntary
  • Suppliers will follow all local employment laws regarding minimum age requirements, wages, overtime benefits and the number of hours worked in a seven day week
  • Suppliers will from time to time certify that they conform to the expectations above.
  • Suppliers must be able to demonstrate compliance with this policy at the request and satisfaction of Vitality.  

Vitality will maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking.  Vitality will promptly and thoroughly investigate any claim or indication that a supplier is engaging in human trafficking or slave labour.  If any supplier is found in violation of this policy, Vitality will take prompt, remedial action to address the violation.
Vitality will provide ongoing training to its employees on the laws and Vitality’s policy against human trafficking and slavery.
Given the nature of our business, our board and management teams throughout the various parts of the Vitality Group believe that there is an extremely low likelihood of there being any involvement in slavery or human trafficking either within our group or within the supply chains that we utilise to deliver our services to our customers.

Our company structure
The Vitality Group in the United Kingdom consists of the following companies;

  • Discovery Group Europe Limited
  • Discovery Holdings Europe Limited
  • Vitality Corporate Services Limited
  • Vitality Health Limited
  • Vitality Life Limited
  • Vitality Health Insurance Limited
  • Insure Your Health Limited

Ultimately these firms are owned by the Discovery Group which is based in South Africa.

We employ around 1500 employees across a number of locations in the United Kingdom and our primary offices are in Bournemouth, London and Stockport. The Group turnover is over £500M and we insure over 850,000 customers.

Our business
Companies in the Vitality Group are involved in the provision and distribution of private medical insurance, life insurance and protection insurance to customers based in the UK. Our insurance plans are purchased by private individuals, SMEs and large corporate customers.
All our insurance plans include “Vitality” which is our wellness programme that helps you to understand your health, makes it cheaper and easier to get healthy and rewards you for making healthy lifestyle choices.

Our supply chains
Our supply chains that support our service delivery are limited and include a small number of 
Offshore firms that provide IT support and “back office” functions such as invoice processing and plan administration
Business partners who support our Vitality programme 

Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking at any stage in our supply chains or in any part of our business. We have in place a Vitality Anti-Slavery Policy that reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. 
Additionally we have a Supplier Code of Conduct that outlines the expectations that we have of our suppliers in areas such as;

  • Health, safety and the environment
  • Bribery and corruption
  • Financial Crime
  • Employment Standards

Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we carry out risk-based due diligence that will incorporate where necessary an assessment as to any potential risk of slavery and human trafficking. 
We have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers. 

Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have a supplier monitoring programme that will involve periodic reviews of our suppliers.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. 

Further steps
Our intention in the coming year is to ensure that our suppliers maintain their adherence to our Supplier Code of Conduct and to further develop our processes and procedures to ensure that we identify and eliminate risks related to slavery and human trafficking. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 30 June 2017.

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