Employee Privacy by Design: Guidance for Employers Beginning to Comply with the California Consumer Privacy Act

Sheppard Mullin Richter & Hampton LLP

On September 13, 2019, the California Senate and Assembly unanimously passed an amendment to the California Consumer Privacy Act (“CCPA”) that places onerous obligations on employers and entitles employees to statutory damages for data breaches.  The landmark measure—AB 25—awaits Governor Newsom’s signature (or veto).  Regardless of whether AB 25 is signed into law, CCPA applies to employee data and employers have until January 1, 2020 to comply.  This article explores how the California Consumer Privacy Act impacts existing employee privacy rights and how employers can begin to develop a holistic privacy compliance program.

What Businesses Are Covered by the California Consumer Privacy Act?

The CCPA covers for-profit “businesses” who meet any one of the following thresholds:

  • Gross annual revenue exceeds $25 million; or
  • Buys, receives, sells, or shares personal information of 50,000 or more consumers, households, or devices; or
  • Derives 50% or more of its annual revenue from selling personal information.

Businesses do not have to be located in California for CCPA to apply.  CCPA applies if one of the foregoing thresholds is met and the company has “consumer” data covered by the Act.  Under CCPA, “consumers” is broadly defined as any “natural person who is a California resident.” (Civ. Code § 1798.140(g).)

Are Employees “Consumers” Under CCPA?

Since CCPA’s passage in June 2018, there has been fierce debate about whether “consumers” include employees.  AB 25 has laid that debate to rest and made clear that “a natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business” would immediately receive some rights under the CCPA. (Civ. Code § 1798.145(g)(1)(A).)  In 2021, such individuals would be afforded full rights under the CCPA. (Id. at § 1798.145(g)(4).)  If AB 25 is vetoed, then these individuals will receive all rights under CCPA on January 1, 2020.  For simplicity, when we refer to “employee data” throughout this article, we intend to include applicants, current/former employees, independent contractors and owners/directors/officers.

Understanding Employee Privacy Rights – The Beginning of the End

In the Golden State, employees have long enjoyed greater rights to privacy and statutory rights to inspect employment records.  Like all Californians, an employee’s right to privacy begins with the California Constitution and is bolstered with various laws.

Employment records are deemed confidential and protected from disclosure absent a subpoena and consumer notice. Civ. Code Proc. § 1985.6(e).  Employees also have a statutory right to inspect the following employment records: payroll records (Lab. Code § 226); documents signed during employment (Lab. Code § 432); records related to performance or a grievance (Lab. Code § 1198.5); and OSHA records for employee exposures to potentially toxic materials (Lab. Code § 6408(d).).  Failure to comply with these inspection rights gives rise to statutory damages.  For example, Labor Code 226 requires employers to allow inspection of payroll records within 21 days after a request is made, or else the employee is entitled to $750 in statutory damages.  Until now, an employee’s right to inspect employment records was limited to the foregoing categories.

CCPA dramatically expands employee rights in three significant ways: (1) it requires mandatory privacy notices and disclosures about the data collected by employers and purpose for collection; (2) it provides for statutory damages ranging from $100-750 if sensitive personal information is breached; and (3) it expands the right to request access/deletion of personal information.

Mandatory Employee Privacy Notices Beginning January 1, 2020

Employee privacy disclosures and appropriate use policies are nothing new.  Such policies are typically used to inform employees of workplace monitoring and diminish expectations of privacy. California courts reinforce the importance of employers maintaining and widely publicizing an employee privacy notice with respect to the use of technology in the workplace.  Courts have consistently upheld an employer’s right to monitor its employees’ computer use and override other privacy/confidentiality interests so long as there is a clear policy that employees have no expectation of privacy to data transmitted on company systems.

AB 25 will expand the scope and content of such employee privacy policies.  As of January 1, 2020 employee privacy notices must also disclose:

  • The categories or personal information the company has collected; and,
  • The purposes for which the categories of personal information will be used.

“Personal information” is omnipotently broad under CCPA and includes “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer.” Civil Code 1798.140 (o)(1).  The definition goes on to identify 11 categories and data elements like “professional or employment-related information,” “education information,” “identifiers,” “characteristics of a protected category,” “biometric information,” “internet activity,” “inferences drawn regarding a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes,” and “geolocation data,” to name a few.  Simply put, employers must disclose all categories of personal information it collects, its purpose, and how the information will be used.

Enforcement.  For now, there is no private right of action for failure to comply with these rights.  Instead, the Attorney General has sole and exclusive jurisdiction to investigate these violations.

Statutory Damages ($100-750 per Consumer) for Data Breaches Beginning January 1, 2020

In 2002, California passed the first data breach notification law in the world (see Civ. Code § 1798.81.5) and required businesses to “reasonably secure” personally identifiable information.  That law has evolved through the years, and today requires businesses to notify consumers (including employees) in the event any of the following sensitive personal information is accessed by an unauthorized user:

  • An individual’s first name or first initial and his or her last name in combination with any one or more of the following data elements, when either the name or the data elements are not encrypted or redacted:
    • Social security number;
    • Driver’s license number or California identification card number;
    • Account number, credit or debit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account;
    • Medical information; or
    • Health insurance information.
  • A username or email address in combination with a password or security question and answer that would permit access to an online account.

Enforcement.  CCPA gave the old law a new (and expensive) attitude by providing consumers with a private right of action to recover statutory damages ranging from $100-750 per incident, per employee, if any of the information listed in the breach statute is subject to unauthorized access or disclosure. (Civ. Code § 1798.150(a)(1).)  Similar to PAGA, CCPA allows consumers to bring a cause of action on behalf of others similarly situated which will make these claims ripe for class action litigation.

Employee Rights to Access & Request Deletion of Data Beginning January 1, 2021

In addition to the disclosures above, AB 25 amends the CCPA to extend full protection and statutory rights to applicants, employees, and independent contractors, including:

  • The right to request a business disclose what personal information the company has collected;
  • The right to know what personal information is being sold or disclosed and to whom;
  • The right to request and receive a copy of all of the above information in a readily useable format;
  • The right to request that the company delete their personal information (the right to be forgotten);
  • The right to opt out of the sale of their personal information; and,
  • The right to be free from retaliation for exercising any rights.

The obligation to comply with a deletion request is subject to numerous exceptions, including the right to keep data that must be maintained for other legal purposes or is consistent with the internal purpose for which it was collected.  The majority of employee or applicant data will likely fall into one of these two exceptions.

Enforcement.  For now, there is no private right of action for failure to comply with these rights.  Instead, the Attorney General has sole and exclusive jurisdiction to investigate these violations.

Beginner’s Mind:  What Can Employers Do to Prepare for CCPA?

Every day we get a chance to begin again.  Below is actionable guidance to kickstart your employee privacy by design program or update existing privacy programs:

  • Data Mapping. Maya Angelou once said “if we know better, we do better.”  If we know what data our organization maintains, we can do a better job meeting our legal obligations under CCPA.  Document a comprehensive inventory of employee data.  Knowing what employee data your organization collects is critical for two reasons: (1) disclosure obligations and (2) security obligations.  A business cannot secure data if it does not know where it lives.  Human Resources questionnaires or live interviews can help solicit feedback from key stakeholders to identify personal information collected for payroll, benefits, HR, tax, IT and other employment purposes.  Once you know how employee data flows in and out of organization, prepare a visual diagram to help navigate other tasks.
  • “Reasonably Secure” Sensitive Employee Data. Reasonable security for sensitive data is not a new requirement, but the risk imposed by CCPA puts security at the top of our list for immediate action.  After data mapping is complete, classify as “sensitive” any data that includes protected elements like Social Security Number, Drivers’ License Number, financial information, health/insurance information, or username/password.  As previously reported, the California Attorney General opined in a 2016 Data Breach Report that “reasonable security” of sensitive data includes encryption, multi-factor authentication and compliance with Center for Internet Security’s Critical Security Controls.  Consult with a qualified cyber security consultant to conduct a “reasonable security” assessment for employee data.
  • Vendor Management. CCPA has flow-down provisions that require you to understand how third parties use, share and secure that data.  Identify third parties and vendors that receive your employee or applicant data (e.g., payroll companies, health/benefits/wellness providers, HR consultants, staffing agencies, etc.).  Once identified, conduct vendor inquiries and diligence about how they use, share and secure the data.  CCPA requires specific language be included in third party agreements to qualify as a service provider (which offers some safe harbors for CCPA violations).  To the extent third parties receive sensitive data like Social Security Numbers, Drivers License numbers, financial information, health information, etc. make sure they have implemented strong security to protect the data.  For example, a new threat is targeting a known vulnerability that is commonly used to support Human Resources, applicant and recruiting software and applications. Confirm with your vendors they have mitigated the risk of the XML External Entity Processing vulnerability. Applicant data contains a treasure trove of sensitive data and notice is required if that data is breached—even if the breach occurs on your vendor’s website and not your own systems.
  • Data Minimization Principles. All good privacy by design programs reduce the amount of data collected to the minimum amount required to achieve its objective.  Consider updating and enforcing your document retention policies to reduce the amount of data maintained.  In the employment context, make sure former employee files are routinely destroyed pursuant to the retention schedules.  Also, analyze whether the benefits of collecting data outweigh the risk.  If so, limit the amount of data collected and maintained.
  • Update Employee Privacy Policies. Dust off existing employee privacy policies and include disclosures about categories/types of information collected and the purpose for its collection.  Whether in employee handbooks, stand-alone disclosures, onboarding documents, or online privacy policies, business should update their disclosures to ensure they provide all the necessary information required by CCPA and other relevant privacy laws.
  • Applicant Privacy Disclosures. Similar to employees, applicants also must receive disclosures about data collected and its purpose for collection.  Consider including disclosures on application forms or landing pages for online applications.  Confirm any third party hosted application or recruiting platforms are CCPA compliant and have signed a CCPA Privacy & Security Addendum to qualify as a “service provider.”  You can also include CCPA disclosures on a separate stand-alone form.  For reasons explained in our previous article, do not include CCPA with FCRA/ICRA disclosures.
  • Independent Contractor Disclosures. As explained in our recent article, AB 5 codifies Dynamex, and makes classification of independent contractors difficult in California.  Given the anticipated wave of litigation expected, make sure to update any independent contractor agreements to confirm they are CCPA compliant and make adequate disclosures about data collection.

The Beginning is Always Today

All good stories have a beginning, middle and end.  Employee privacy is no exception.  We find ourselves at the beginning of a movement that will continue expanding employee rights.  If AB 25 is signed, this will only provide a temporary reprieve for employers under the CCPA.  However, by January 1, 2021, all applicants, employees, and independent contractors will have full rights under the CCPA, which include the rights to request and delete information.

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.

© Sheppard Mullin Richter & Hampton LLP | Attorney Advertising

Written by:

Sheppard Mullin Richter & Hampton LLP
Contact
more
less

Sheppard Mullin Richter & Hampton LLP 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.