The Internal Market Information system (IMI) makes it easier for authorities to contact each other across the EU and share information.
European citizens and businesses alike benefit from the opportunities offered by the single market. For single market legislation to work as intended, member state administrations need to be able to cooperate closely. To support them in their cooperation, the European Commission created the Internal Market Information system (IMI).
Under Article 29 of the Service Directive, member states are obliged to provide mutual help to each other if requested and this must be achieved through electronic means.
What does the IMI do?
IMI is an online, secure messaging system developed by the European Commission. It allows national, regional and local authorities to communicate quickly and easily with their counterparts in other member states. IMI is accessible via the internet without the need to install any additional software.
IMI has been developed to:
- enable member states to help each other
- promote confidence and trust through increased communication
- overcome existing barriers for example administrative and working cultures, different languages and a lack of clearly identified partners
- reduce administrative burdens
- increase efficiency and effectiveness in cooperation between member states
IMI now has 7,000+ registered authorities and 12,000+ registered users. There are more than 400 UK registered authorities on the system.
How does IMI work?
IMI helps users to:
- find the right authority to contact in another country
- communicate with them using pre-translated sets of standard questions and answers
- you’re an authority in the UK wanting information from an Italian body
- you select a standard question from the system in English
- the Italian authority sees the question and corresponding reply options in Italian
- you receive a reply to your question from them in English
Member states have helped develop IMI and the system offers uniform working methods agreed by every EU country.
Who is IMI for?
IMI is used by competent authorities at national, regional and local level in the EU plus Iceland, Liechtenstein and Norway, which deal with the specific legislation IMI supports.
Registration in IMI is only open to these authorities and has to be approved by an IMI coordinator in the relevant country.
44% of information requests submitted via the IMI are answered within 1 week and 62% are answered within 2 weeks. In a recent survey (June 2012), 86% of respondents said that IMI was easy to use.
Some of the advantages in registering on IMI are that:
- it ensures your authority is trained and prepared for receiving ‘real’ requests for information
- it helps to spread best practice across all member states
- it can help to overcome language barriers on issues such as UK workers looking to work in other EU member states or vice versa
- your feedback will help shape future versions of the system, ensuring it meets the needs of your authority
How do I register my authority?
Registration to use the IMI system is a simple process: send an email to firstname.lastname@example.org indicating your wish to register.
You will get a brief form to fill in, after which you will be granted access, be able to register other users from within your authority and also use the system to send requests.
Who should I contact in the event of an IMI query?
Please email email@example.com if you have any queries or issues with using the IMI system, for example access problems or difficulties in locating the correct authority.
How do I use the system for training/practicing without sending a real request for information?
The European Commission has developed a training database that allows you to practice using the IMI system and understand the processes involved.
Access to the training database requires a separate login, which can be obtained by emailing firstname.lastname@example.org.
Other training materials
The European Commission has prepared some training materials. These are easy to use and take you through the whole process of registration to sending and receiving a request, as well as more detailed aspects of the IMI, such a partial replies and forwarding a request. We welcome your feedback on these training packages and suggestions for improving them.
Services Directive notifications
In August 2013, the Services Directive notification procedure became part of the IMI. This means that you should use the IMI system to submit any notifications required under the Services Directive.
Using the new procedure you can:
- view and comment on notifications sent from another member state
- create and send notifications for other member states to review
- you should send notifications well in advance of any new legislation/proposal
- you should allow 3 months for comments (the notification will be automatically closed on IMI after 3 months)
- the Commission may ask a member state to modify or withdraw legislation/proposals if it thinks that it contravenes the requirements of the Services Directive (Provision of Services Regulations 2009)
For further details on the new procedure see the ‘Guidelines for the use of the Services Directive notification function in IMI’.
National Liaison Point
A UK National Liaison Point (NLP) based in BIS monitors the use of the IMI system for administrative cooperation requests involving the UK and is on hand to help out with any problems or disputes. The NLP can direct competent authorities in other European countries to their opposite number or to the relevant authority in the UK, and vice versa. The NLP will also be able to liaise with their counterparts in other European countries if UK authorities experience delays in obtaining information from other authorities. You can contact the NLP by emailing email@example.com.
The IMI regulation on administrative cooperation came into force in December 2012. This regulation requires all registered IMI users that hold information on individuals to tell them how:
- their personal data is being processed in IMI
- to exercise their right to access their information
- to ensure that individuals are able to exercise their right to have both inaccurate or incomplete data corrected, and unlawfully processed data deleted
This is in accordance with relevant national legislation, which in the UK is the Data Protection Act 1998.
What must authorities do?
The regulation requires that any requests for correction or deletion of information should be done as soon as possible and no later than 30 days after the request has been received. If your authority holds personal information about individuals and uses the IMI system to make enquiries, you must ensure that your authority has a process in place to inform individuals about their rights.
Helpful guidance on Data Protection
There are Guidelines on Data Protection for IMI users available from the EU.
The Information Commissioner’s Office has also published a Code of practice on data protection. Although it is up to each competent authority to decide how to convey this information, a simple solution would be to include something in a privacy notice. A privacy notice is a statement that individuals are given when information is collected about them. We recommend that authorities add some text to their existing privacy notices to inform data subjects about the exchange of information via IMI.
It is up to each authority to decide what to include in their privacy notices, but the following are some important points that you should include:
- IMI is a web-based portal developed by the European Commission - it enables messages and information to be exchanged between authorities in a secure environment, and complies with data protection rules
- competent authorities will use the system to exchange information on service providers that are in scope of the Services Directive - authorities must have good reason to request information, and provide justification when submitting a request
- only competent authorities involved in a request for information can see the personal details of a data subject
- all personal data is automatically deleted from the system 6 months after the closure of a request
- UK competent authorities are obliged to notify data subjects if they supply sensitive data about them, for example relating to disciplinary action or criminal sanctions, to other authorities
Amending your ICO notification
All UK bodies that process personal data should already be registered with the ICO. As exchanging information via IMI will be a new use of personal data for most competent authorities, you should amend your notification entry with the ICO to reflect this. More information on amending your ICO notification is available from the ICO website.
The Knowledge Hub discussion forum
We have set up a dedicated forum on the LGA website to enable local authorities plus other competent authorities to provide peer support and share information, best practice and knowledge development relating to the services directive in a secure environment.
To register, visit the website and follow the registration instructions. After registration, search for ‘EU Services Directive’ to see and interact with our online community. If you have any queries, please email firstname.lastname@example.org.
The European Commission IMI website is a good source of further information on data protection issues, training materials and history of the Services Directive.