Skip to Content

Legal and
security

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, as defined in the Act, is Vitality Corporate Services Limited (trading as VitalityHealth and VitalityLife) of 3 More London Riverside, London SE1 2AQ.

Vitality Corporate Services Limited, Vitality Health Limited, Vitality Health Insurance Limited and Vitality Life Limited registered with the Information Commissioner as Data Controllers, (“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 private health insurance plans, life insurance and protection plans, investment products, our range of incentives and benefits, our website located at www.vitality.co.uk (“our site”) and our Vitality mobile applications for iPhone OS and Android OS (collectively referred to in this privacy policy as the “Services”).

Where appropriate, we’ll ask for your consent to use your personal information, at the point where we collect it. If the reasons for us processing your personal information are consistent with what you’ve asked us to do, we’ll explain this so that you fully understand how we’ll use your information.

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 getting in touch 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 health, mental health and your lifestyle. You can choose whether to supply or withhold any sensitive personal data. However, withholding information may limit the Services we can offer you.

(ii) Information we get from other sources

We may also get information about you from third parties who help to provide the Services. These third parties include but are not limited to: existing service providers, prospective new Vitality partners, sub-contractors in technical payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies. We’ll always ensure that any data we receive has been collected lawfully and fairly, in a way that conforms to your rights under the Data Protection 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:

  • for administration and management of our Services;
  • where we need a GP report, we will ask you for your permission, which will be managed in line with Access to Medical Report Act;
  • as part of our business processes and relevant activities including auditing, business planning, accounting and transactions;
  • to be compliant 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 engaging with the product 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 provide to you and others, and to deliver relevant advertising to you if you have given us your permission to receive marketing from us;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

This list isn’t definitive and could change if our business, legal or regulatory needs change. We will always ask for your consent first if we wish to use your personal information in a way we have not told you about. We may also combine information we get from other sources with information we collect about you for the reasons shown above.

Processing claims

When you submit a claim we may have to pass information about you to those involved in your treatment or care and/or your representative (if you have one). We’ll do this in a secure and confidential way.

Any insured dependant aged 16 or over has the right to confidentiality for their claims and information. To assert this right, the insured dependant should contact our customer services team.

If you have another insurance plan covering the same costs that you claim from us, we may also pass your relevant personal information to the provider, to ensure we only pay our share of the claim.

How we may retain and remove personal data

We hold data in various ways. These include electronic databases, computerised files and paper files. We’ll keep your data for the term of your policy and for a further period of time specified by regulation. We’ll remove all personally identifiable data by using our approved company processes, to make sure we take all reasonable precautions to protect its confidentiality. We may keep non-personally identifiable data for research and statistical reasons or to improve our Services.

Who we may share data with

We may pass data to third parties so that we can provide the Services. These include:

  • service providers;
  • benefit partners to provide you with the rewards you are entitled to;
  • technical payment and delivery service sub-contractors;
  • analytics providers and search information providers;
  • credit reference agencies when they need to assess your credit score and where this is a condition of entering into a contract with you;
  • any legal or regulatory organisation, where it’s our legal responsibility to pass on or share your personal data with them. This includes sharing information with other companies and organisations for the uses of fraud protection and credit risk reduction.

If you have a financial/insurance adviser we will send copies of your plan or renewal to them. We may pass on claim details to them, although we won’t provide any medical information without your consent. We may also pass on information about you or others also covered by the plan to third parties (for example other insurance companies) for the uses of fraud protection or improper claims.

To help you make the most of your Vitality plan, we’ll share some data with:

  • financial/insurance advisers, but only with your consent as they’re well-placed to promote the benefits of the Services and make sure you get the most out of your plan;
  • prospective new Vitality partners, in order for us to develop and improve the Services; where your insurance is paid for by an employer, we may provide non-personally identifiable data to them, so that they can assess the impact of Vitality on their workforce.

In all cases, we use privacy-enhancing technologies as promoted by the Information Commissioner's Office (“ICO”) and which conform to EU guidance.

Where we store your personal data

We may transfer and store the data that we collect from you to a destination outside the European Economic Area ("EEA"). Such transfers are conducted in compliance with the methods approved by the Information Commissioner. Suppliers, operating outside the EEA, may also process your data. They will do this on our behalf under contract to VCSL. Among other things, they may be involved in: delivering the Services, processing your payment details, and providing support services. We’ll take all reasonable and necessary steps to make sure we treat your data securely and in a way that conforms to this privacy policy.

Marketing

To keep you informed with product or partner updates and offers we would like to use your personal information to contact you. You have the right to ask us not to process your personal data for marketing uses. Before collecting your data, we’ll always tell you if we intend using it for marketing reasons. You can exercise your right to stop us using your data by checking certain boxes on the forms we use to collect it. You can also log on to the Member Zone and send us a secure message; contact our customer services team or email us at marketingchoices@vitality.co.uk

Your rights to ask for, check and change your personal data

You have the right to ask for a copy of the data we hold about you, as well as asking us to correct any inaccurate data. You can use your right to access your data under the terms of the Act. To access your data, please contact the Data Subject Access Request team by email at: dsar@vitality.co.uk or by post at: DSAR Team, St Christopher House, 217 Wellington Road South, Stockport SK2 6NG

Changes to our privacy policy

We’ll post any changes we may make to our privacy policy in future on vitality.co.uk. Where appropriate, we’ll also let you know by email or post. Please check back regularly 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:

Email: dsar@vitality.co.uk
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.

2017

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

Discovery Group Europe Limited SFCR for the year ending 30 June 2017

2016

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.

Training
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.

Where to next?