ECB releases procurement guidelines for selecting service providers in cyber-resilience testing

by Dentons
Contact

Dentons

The European Central Bank (ECB)’s publication on May 2, 2018 of its framework for “Threat Intelligence-Based Ethical Red-Teaming” (TIBER-EU Framework), which is discussed in further detail in the first1 of this series of Client Alerts, marked a definitive step by the ECB, in this instance acting in its central banking as opposed to its Banking Union supervisory capacity,2 to lead the way on setting cyber-resilience standards.  

At the heart of this new “voluntary” framework, which aims to apply to in-scope authorities as well as financial services firms, including financial market infrastructure providers, are that TIBER-EU tests are intelligence based ethical hacking. In-scope entities are expected to embed a “comply or explain” approach to the TIBER-EU Framework. 

The TIBER-EU Framework only recognizes cyber-resilience tests that are carried out by service providers of Red Team Tests (RT) as well as Threat Intelligence (TI). These must be selected and retained in accordance with the “TIBER-EU Framework Services Procurement Guidelines” (the Procurement Guidelines), which was published without consultation in August 2018.  This Client Alert discusses the current version of the Procurement Guidelines’ requirements and the ECB’s expectations as they may supplement existing EU and national rules on selecting and retaining service providers.

Some of the contents may be familiar, especially for regulated firms that have a strong compliance program in place for regulated outsourcing and delegation arrangements but other requirements and expectations of the ECB may be quite technical and prescriptive. As with recent ECB rulemaking instruments or other guidelines that however set supervisory expectations and may read like rulebooks, the TIBER-EU Framework and the Procurement Guidelines use the verb “should” which in most cases means “shall”3 or “must”.  In certain languages, “should”, is read to imply a degree of optionality. At present, the TIBER-EU Framework nor the Procurement Guidelines refer to international work of say the Financial Stability Board, who on 2 July 2018 launched its own consultation on a “Cyber Lexicon”4 of ca. 50 core terms relevant to cyber-security and cyber-resilience.  

What do the Procurement Guidelines require?  

The Procurement Guidelines emphasize the need for in-scope entities, in particular, those that plan to apply the TIBER-EU Framework to their global operations, that they must observe all obligations applicable to them. The Procurement Guidelines are currently split into the following three parts:

  1. Stipulate requirements and standards that RT/TI providers must meet to deliver recognized TIBER-EU tests;
  2. Offer guiding principles and selection criteria that in-scope entities should observe, in addition to requirements in respective and applicable legal and regulatory requirements, when procuring services from prospective RT/TI providers; and
  3. Provide questions and checklists relevant for contractual arrangements that entities are free to apply in their due diligence and when formalizing the procurement process with RT/TI providers.

The role of the TI provider

Conducting effective red teaming and cyber-resilience risk assessments in a manner that meets the expectations set by the TIBER-EU Framework requires accurate threat intelligence. TI providers thus play an important role.  The Procurement Guidelines specifically state:

“Creating accurate and realistic threat intelligence is a complex activity. This means that the TI provider must have adequate knowledge of the threat actors, their motives and their TTPs [tactics, techniques and procedures], as well [as] an understanding of how the core elements of the financial system interact and operate. In addition, the TI provider must have a good insight into the targeted entity. It needs to know for example: what the target’s critical functions are; how the target operates; who the crucial employees are and whether they are “usable” for the attack; and what the target’s vulnerabilities are.”

Comprehensive threat intelligence assists the RT provider with quality information allowing it to simulate a real life and realistic attack on the entity’s live systems that underpin the “critical functions” and their cyber-resilience, which is the ethos of what the TIBER-EU Framework aims to test. The Procurement Guidelines set out that the TI provider meet the following qualitative requirements and, where possible, only accredited and certified TI providers should be chosen. 

The Procurement Guidelines clarify that the ECB expects in-scope entities to:

  1. Document the due diligence conducted prior to selecting a provider –preferably using the questions in the Annex
  2. Evidence how TI providers meet the following requirements in the table below
  3. Monitor and record how the TI provider performs against key performance indicators in service level agreements:
Who? Requirements to be fulfilled according to Procurement Guidelines
The TI provider(at the company level)
  • At least three references from previous assignments related to threat intelligence-led red team tests
  • Adequate indemnity insurance in place to cover activities that were not agreed upon in the engagement and service level arrangements and/or which stem from misconduct, negligence etc.
  • Evidence a robust understanding and application of information governance, security and risk management
  • Adhere to professional codes of conduct such as the Code of Conduct for Ethical Security Testers or the Open Source Intelligence and Research Association’s - OSIRA Code of Conduct
The TI provider’s Threat Intelligence Manager (the TIM) designated for the TIBER-EU test and responsible for its end to end management
  • The TIM leads and has oversight of the TI provider’s activities for delivering a TIBER-EU test
  • The TIM must have sufficient experience in threat intelligence – the expectation is at least five years of experience in threat intelligence, of which at least three years are in producing threat intelligence in the financial services industry
  • The TI provider will provide:
    • a current CV of the TIM and at least three references in relation to the TIM’s work on previous assignments and specifically red team testing
    • background checks on the TIM – which may be simplified and/or enhanced disclosure
  • The TIM must have appropriate recognized qualifications and certifications (as set out in Annex 1 to the Procurement Guidelines)
The TI provider’s Threat Intelligence Team (the TIT)5 (all members other than TIM responsible for delivering the TIBER-EU test
  • The TIT must collectively evidence sufficient experience and each member must have at least two years of experience delivering threat intelligence services
  • The TI provider must provide a current CV for each team member as well as background checks
  • The relevant team composition should be multi-disciplinary and evidence a broad range of skills, including “OSINT, HUMINT and geopolitical knowledge.” OSINT refers to open source intelligence gathering of information derived from public and/or predictive sources. HUMINT refers to “human intelligence” gathering of data. The Procurement Guidelines’ “Recommended Questions” also refer to SIGINT i.e. signals intelligence capabilities
  • Ideally the team members are expected to have appropriate recognized qualifications and certifications for threat intelligence and professional experience in delivering threat intelligence for red team tests

 

The Procurement Guidelines are quite prescriptive in what characteristics the TI provider must comply with when compiling threat intelligence. It also requires that the threat intelligence report be delivered in a manner that complies with the EU’s General Data Protection Regulation (GDPR).

The role of the RT provider

RT providers plan and execute a TIBER-EU test on the target’s systems, services, processes, technologies and people that have been agreed as being in scope of the exercise. As the test builds on the report of the TI provider, it differs from conventional resilience testing in that it aims to mimic the tactics employed by a real-life attacker targeting an entities critical functions.

The Procurement Guidelines therefore expect that RT and TI providers demonstrate a willingness to work closely with one another in preparing the Red Team Test Plan as well as prior to and during the test phase itself and ultimately when delivering the Final Report.

As with the expectations set of the TI provider and standards to follow prior to and during the appointment, the Procurement Guidelines sets the following requirements that a RT provider must be able to fulfil: 

Who? Requirements to be fulfilled according to Procurement Guidelines
The RT provider
(at the company level)
  • At least five references from previous assignments related to intelligence-led red team tests
  • Adequate indemnity insurance in place to cover activities that were not agreed upon in the engagement and service level arrangements and/or which stem from misconduct, negligence etc.
  • Evidence a robust understanding and application of information governance, security and risk management
  • Adhere to professional codes of conduct such as the Code of Conduct for Ethical Security Testers or the Open Source Intelligence and Research Association’s - OSIRA Code of Conduct
The RT provider’s Red Team Test Manager (the RTTM) designated for the TIBER-EU test and responsible for its end to end management
  • The RTTM leads and has oversight of the TI provider’s activities for delivering a TIBER-EU test
  • The RTTM must have sufficient experience in red team testing – the expectation is at least five years of experience in testing, of which at least three years are in leading red team tests in the financial services industry
  • The RT provider will provide:
    • A current CV of the RTTM and at least three references in relation to the RTTM’s work on previous assignments and specifically red team testing
    • Background checks on the RTTM – which may be simplified and/or enhanced disclosure
  • The RTTM must have appropriate recognized qualifications and certifications (as set out in Annex 1 to the Procurement Guidelines)
The TI provider’s Red Team (all members other than RTTM responsible for delivering the TIBER-EU test
  • The Red Team must collectively evidence sufficient experience, and each member must have at least two years of experience delivering red team testing
  • The RT provider must provide a current CV for each team member as well as background checks
  • The relevant team composition should be multi-disciplinary and evidence a broad combination of skills, including reconnaissance, threat intelligence, risk management, exploit development, vulnerability analysis, penetration testing, social engineering etc.
  • Ideally the team members are expected to have appropriate recognized qualifications and certifications

 

The Procurement Guidelines place an emphasis on TI providers but notably RT providers’ multilingual capabilities as well as an expectation that they have a breadth of experience in financial services but also in other sectors. This aims to ensure that providers can borrow tactics and adapt these to TIBERU-EU tests. 

Language plays an important part in this, as simulated social engineering attacks, which attempt, by fraudulent means, to obtain sensitive information (log-ins, account details etc.), such as “phishing” need to use language in a manner that is plausible.

Recommended questions and checklists

The Annex to the Procurement Guidelines contain, in addition to a list of certifications and qualifications that relevant team members at RT/TI providers should evidence, recommended questions that in-scope entities can use when selecting providers. Specific requests, which may go beyond existing EU and national level requirements, are for the provider to supply its recruitment policy and process or for providers to also disclose details/results of independent audits of its information security system. 

The Annex also contains a checklist that essentially has heads of terms for the service level agreement to be put in place with the relevant RT/TI provider. The Checklist places a strong emphasis on detailed information security measures and screening of employees to be put in place, detailed measures on whom information can be shared with and when as well as incident response management, continuity of services and exit clauses as they relate to data destruction and more generally.

Outlook

The Procurement Guidelines are just one part of the TIBER-EU Framework. This is a framework, which is expected to evolve in depth and scope of application over time and do so in line with the growing importance of cyber-resilience testing for the ECB as supervisor, financial stability oversight actor and as central bank. Whilst the Procurement Guidelines may be quite prescriptive in parts, some of this may actually be quite welcome in setting goalposts and allowing clients and service providers to engage on more standardized terms.  

For in-scope entities, whether as existing or potential clients of RT/TI providers, much of the compliance challenge will likely be in ensuring that the selection and decision-making process when retaining providers meets the expectations set in the TIBER-EU Framework as a whole. Depending on the extent of measures in place, it may be prudent to diligence relevant existing providers anew so as to meet the expectations of the Procurement Guidelines formally. For RT/TI service providers the Procurement Guidelines present an opportunity to have a much more structured road map on compliance expectations and service level performance monitoring. Some providers may want to consider how to reflect how they meet the ECB’s expectations and possibly also have a standardized Fact Sheet detailing key information and responding to the Questions and Checklists set in the Procurement Guidelines’ Annex. 

Lastly, the ECB may over time become more vocal on where RT/TI providers corporate domicile are located or where the testing facilities are located. This could mean that more specific expectations are communicated beyond “just” the requirement to comply with GDPR or evidence sufficient multilingual capabilities—read proficiency in one or more languages of the EU.


1. See our dedicated coverage from our Eurozone Hub: https://www.dentons.com/en/insights/articles/2018/july/17/central-bank-of-cyber
2. The ECB, in its Banking Union capacity, itself states that it monitors how Banking Union supervised institutions manage their IT risks. This includes cyber-security and thus cyber-resilience. This includes:

  • Continuous off-site supervision and risk assessments;
  • Thematic and horizontal reviews of focus areas (e.g. cyber security, IT outsourcing, data quality); and
  • Targeted on-site inspections (on IT risk areas in general, but also focused on IT security and cyber risk).

3. From where the verb derives its origin.
4. See: http://www.fsb.org/2018/07/cyber-lexicon-consultative-document/
5. For close followers of ECB rulemaking, both in central bank and supervisory capacity, the fact that the ECB does like a good acronym should come as no surprise.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dentons | Attorney Advertising

Written by:

Dentons
Contact
more
less

Dentons 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.