A New Era For Labor Relations? Fisher Phillips Lawyers Predict Fate Of Top 10 Key Issues

by Fisher Phillips

Fisher Phillips

Among the most crucial federal agencies undergoing a transformation under the new presidential administration is the National Labor Relations Board (NLRB). During the eight years of the Obama administration, with the Board stocked with a majority of Democratic appointees, the NLRB issued decision after decision tilting the playing field decidedly in favor of unions and workers. However, the five-member NLRB is poised to soon be led by a majority of Republican appointees, and we expect changes to soon follow.

We polled some of our firm’s foremost thought leaders to discuss 10 specific topics that we expect to evolve for the better in the near future. Employers – both unionized and non-unionized – should pay particular attention to these topics.

Use Of Company Email

Perhaps no Board decision of the recent past has been derided more than 2014’s Purple Communications, which held that employers – whether unionized or not – generally must allow employees to use corporate email systems during non-work time to engage in concerted and protected activity under Section 7 of the National Labor Relations Act (NLRA). As San Diego attorney Chris Conti puts it, “this decision opened the floodgates for organizing activity through corporate email servers.” It also resulted in most employers having to rewrite solicitation policies and rules governing email use, particularly those that restricted email use to “business reasons only,” and created a Catch-22 for employers that want to legitimately monitor email activity but also want to avoid engaging in unlawful surveillance.

In early 2017, the Board once again upheld the decision. But once it has a majority of Trump appointees, Conti expects the Board will eventually issue a decision overturning Purple Communications. “Overturning this decision would bring about a return to normalcy that employers had come to expect since at least 2007,” he says. That year, the Board explicitly held that employees have no statutory right to use their employers’ email servers to engage in protected activity, based predominantly on the employer’s property interest in its own information technology (Register Guard). If Purple Communications is overturned as Conti expects, employers would regain the right to restrict corporate email use for business purposes only, and would be freer to monitor email activity for legitimate reasons without facing unfair labor practice charges. 

Mandatory Class Waivers  

Beginning with 2012’s infamous D.R. Horton decision, the Board has repeatedly struck down arbitration agreements that contain mandatory class and collective action waivers. Todd Lyon, a partner in the Portland office, explains: “The Board has reasoned that requiring employees to enter into such agreements violates Section 7 of the NLRA, preventing them from engaging in protected concerted activity.” Employers have been faced with uncertainty ever since, as the Board continued to strike down mandatory waivers even after they had been overturned by several circuit courts. But in 2016, Lyon explains, a circuit split emerged, when both the 7th Circuit (in Lewis v. Epic Systems Corp.) and 9th Circuit (in Morris v. Ernst & Young LLP) struck down class and collective waivers.

Lyon says there is reason for optimism, even without the pending transformation at the NLRB. “There is a strong likelihood that this circuit split will be resolved by the end of the year,” he says, “because the Supreme Court has agreed to hear arguments on this issue in October. Although employers should be cautiously optimistic after the appointment of Justice Neil Gorsuch, there is no guarantee he will strike down the decisions by the NLRB.” The decision will ultimately decide the question of Section 7’s applicability to class and collective action waivers, and will be binding on the Board. “It’s impossible to predict what the Board will do after the Court issues its decision, as the ruling could take many forms,” says Lyon, “but its new political composition will certainly mean a change from the last eight years of union-friendly precedent.”

Joint Employment Doctrine

Another recent controversial decision from the NLRB came in 2015’s Browning-Ferris Industries (BFI), where the Board vastly broadened the definition of “joint employer” for purposes of collective bargaining and union organizing. A business may now be considered a joint employer if it exercises even “indirect control” over working conditions of another company’s employees, or if it merely reserves the right to do so. As New Jersey’s Alvaro Hasani says, “to be sure, the decision has arguably jeopardized long-standing business models and created a great deal of uncertainty regarding liability risks that companies may not be able to control.”

Hasani explains there are three possible avenues for this decision to be reversed. The case has already been appealed to the D.C. Circuit Court of Appeals, which will likely have the first say on whether the decision should be reversed. However, even if the court upholds the NLRB’s decision, it is likely a newly Republican-controlled NLRB will revert the current broad “indirect control” standard to the more exact “direct control” standard that preceded the BFI decision. A yet faster repudiation may come by way of legislation, such as the “Save Local Business Act” introduced in July. Given the current makeup of Congress and the Trump administration’s announced intention of rolling back joint employer expansions, Hasani believes it is only a matter of time before the BFI decision is repudiated for a more even-handed formulation.

Temporary Worker Organizing

Hand-in-hand with BFI comes 2016’s Miller & Anderson decision, where the NLRB reinstated a union-friendly standard for unionizing temp workers. “The Board ruled that employer consent is no longer necessary for bargaining units that combine regular employees and temporary workers jointly employed by another employer,” explains Hasani. The combined impact of these two decisions means that an entity is more likely to be deemed a joint employer and will be forced to bargain with employees whose terms and conditions of employment are controlled by another entity.

Hasani predicts this decision is likely to be changed by the Republican-controlled Board in the near future. To reverse the decision the Board will have to wait for another similar case to come before it, but Hasani thinks it will be worth the wait for employers. “Given the business necessity for using temporary employees,” he says, “employers would no longer need to engage in a risk-benefit analysis to determine if they should rely on this type of work.”

Confidentiality In Internal Investigations

While the aforementioned cases achieved a certain amount of notoriety, there have been several less prominent decisions that flew under the radar in recent years, but still had a significant impact on labor relations. One such case, identified by Tampa Managing Partner Steve Bernstein, is the Board’s 2015 ruling in Banner Healthcare. “The upshot of this case is that it effectively precludes all employers, union and non-union alike, from compelling employees to maintain a modicum of confidentiality over information exchanged in the course of internal investigations, including those conducted in response to allegations of workplace harassment,” he explains. This works at cross-purposes with years of experience telling employers that complainants are less likely to come forward if their concerns are at risk of dissemination by fellow witnesses during the pendency of the investigation. 

Although the D.C. Circuit Court of Appeals recently had an opportunity to rule on the lawfulness of a general confidentiality policy, it instead chose to overturn the decision on narrower grounds and left the underlying doctrine intact. Bernstein is hopeful, however; “A reconstituted NLRB will soon have the opportunity to reexamine that doctrine in light of broader legal implications, and I hope the new Board preserves the integrity of open-door and EEO policies that are important to all of our clients,” he says.

Workplace Civility Rules

Under the current Board interpretation of Lutheran Heritage, the seminal 2004 decision on workplace civility rules, an employer handbook rule or policy will be held unlawful if employees “would reasonably construe” the rule to prohibit protected Section 7 activities. “This interpretation has led to reasonable rules implemented with the purpose of creating a respectful and well-managed workplace being struck down as illegal,” explains Atlanta’s Josh Viau.

The best predictor of the approach that Trump’s Board will take on workplace rules can be found in the frequent dissents authored as of late by its minority members, says Viau. They included strong disagreements about the way the Obama Board analyzed and decided cases involving employee civility rules. “I would expect the Trump Board, once the opportunity presents itself through the appropriate challenge, to adopt some form of the balancing test that would take into account employers’ legitimate justification for the rule or policy,” he concludes.

Confidentiality And Other Handbook Provisions

Another little-known landmine in many company handbooks is the typical confidentiality policy, restricting employees from discussing certain topics among each other or with members of the public. “Currently, many employer policies run afoul of what the Board considers to be an illegal restriction preventing employees from engaging in protected concerted activity,” explains Danielle Garcia, an attorney in the San Diego office. Board decisions on this topic and several other common handbook policies are all based on the 2015 memo issued by the General Counsel (also known as the “Wendy’s Memo”). 

Once a new General Counsel is in place at the NLRB, Garcia says, we can expect new directives regarding how polices are interpreted. “I’d expect the new Board to interpret handbook policies, including confidentiality provisions, in a less restrictive manner for employers,” she predicts. The changes will come not only from a new directive memo from the incoming General Counsel, but also through the federal courts which are now starting to scrutinize the Board’s recent decisions. Garcia’s prediction: “Current Board precedent forbidding policies that restrict workplace recordings, among other things, will likely be overturned, giving employers more say in their workplaces and more control over their policies and handbooks.”


“The NLRB’s 2011 Specialty Healthcare decision altered the labor landscape by revisiting the way determinations are made about whether proposed bargaining units are appropriate,” explains Louisville partner Ray Haley. In a two-step analysis, he says, the Board will first examine whether members of a petitioned-for unit share a community of interest and are “clearly identifiable as a group.” If an employer should object, they can only enlarge the unit by showing that those excluded “share an overwhelming community of interest” with the petitioned-for group. Haley points out that the Board has long enjoyed substantial judicial deference in matters of unit determination, noting that every federal court of appeals called upon to review determinations made pursuant to the Specialty Healthcare analysis has affirmed the NLRB, including a very recent August 2017 decision by the D.C. Circuit.

Employers might now see a light at the end of the tunnel, however. Two 2016 decisions from the 2nd and 5th Circuit Courts of Appeal displayed a heightened degree of scrutiny when applying facts to the NLRB standard. Haley believes these decisions are a sign of good things to come, especially once the Board is fully reconstituted with a majority of Republican appointees.

“The roadmap for overruling Specialty Healthcare has been clearly laid out by these courts,” Haley says, “and the mischief caused by rote-and-verse application of its test is soon likely to be ameliorated if not in its entirety, then at least in substantial part.”

“Quickie Election” Rules

The adoption of accelerated election rules by the NLRB in April 2015 – dubbed “quickie elections” by disaffected employers and their counsel – has tipped the scales in favor of unions, according to Irvine partner Warren Nelson. The union success rate in elections has risen to 70 percent, no doubt due to the accelerated timeframe for elections that has seen the average campaign shrink from 42 days to between 23 and 25 days. Nelson says this new timeframe impacts both large and small employers, as “smaller employers do not have the administrative staff to gather and produce the required information in the fast-tracked timeframe, and large employers have a massive task of culling their records to accurately provide required information.” He points to the “Draconian penalties” imposed for failure to meet these timelines as another example of how the scales are not presently in balance.

The good news? “I predict that the newly reconstituted Board will focus on the election schedule and shift it to a more manageable timeframe,” says Nelson. Establishing this new procedure will take time, he says – “expect at least three to six months for formal rulemaking to be followed.”

Student Organizing

The final issue to keep an eye on is of particular importance to institutions of higher education. As explained by Boston Managing Partner Joe Ambash, for decades the NLRB declined to find students who serve as teaching and research assistants at private universities to be employees under the NLRA, but all that changed in 2016.

In the now-infamous Columbia University decision, the Board ruled that such students were employees under the Act, and thus able to organize into unions. As Ambash says, “this decision, which was aggressively pursued by the unions for years, opened up a floodgate of graduate assistant organizing at private sector institutions across the country.” The Columbia decision has since been expanded to cover undergraduate resident advisors, so it follows that under current Board logic, virtually any graduate student or undergraduate who performs services for a private college or university for compensation – including, presumably, free housing – could be considered an employee eligible to be represented by a union.

“This is expected to change under the Trump Board,” says Ambash. “I anticipate that the newly formulated Board will eventually reverse the Columbia decision.” The implications for higher education in this battle are significant, and could help shape the academic experience of private sector students for decades to come.

Written by:

Fisher Phillips

Fisher Phillips on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.