Executive Labor Summary: 2015 Wrap-Up Edition

by Constangy, Brooks, Smith & Prophete, LLP
Contact

NEWS & ANALYSIS

U.S. Department of Labor moves forward with new "persuader" regulations, expected in March 2016 - As we have previously reported, the U.S. Department of Labor has long wanted to revise the "persuader" reporting rules under the Labor Management Reporting and Disclosure Act. The DOL announced in a regulatory agenda issued toward the end of 2015 that it expects to issue the persuader rule in March (that's two months from now). Current regulations require employers and their labor consultants who engage in "persuader activity" to file extensive reports about their use of consultants and lawyers. However, the current regulations contain an "advice exemption" for attorneys and consultants who assist employers in labor relations activities so long as the activities are "advisory" to the employer (that is, the attorneys and consultants communicate to the employer and do not directly communicate with employees).

The proposed regulations are expected to narrow that exemption, essentially to limit exempt "advice" to providing representation in legal and administrative labor-related proceedings. Such a narrowing will largely swallow the advice exemption and mean that many more entities – employers, attorneys, and consultants – will have an obligation to report extensive and detailed financial information on labor relations activity, expansively defined, on mandatory DOL forms. The reporting obligations are huge, costly to those subject, and come with potential criminal sanctions for failure to comply.

Since at least 2011, the DOL has held back on issuing its new final persuader regulations, presumably because of the political and legal firestorm that is expected. Opponents of the new regulations point out that the new interpretation of the advice exemption will encroach on the attorney-client privilege and deter smaller employers from seeking legal advice in labor matters, which is expected to hinder employer effectiveness in union campaigns while also increasing the risk that employers will commit unfair labor practices because they don't have the benefit of legal advice. The regulations have now been submitted to the Office of Management and Budget, a near-final step in the process. Court challenges are likely, but employers, their counsel, and their consultants should begin to prepare if they have not done so already.

Is Volkswagen-Chattanooga "drawing a charge" after UAW’s "micro-victory"? - On December 14, the National Labor Relations Board certified the results of the UAW’s December 4 election victory (108 for the union, 44 against) for a skilled maintenance bargaining unit at Volkswagen's plant in Chattanooga, Tennessee. The plant has approximately 1,400 total production and maintenance workers, but the UAW focused on the "micro" unit of skilled maintenance workers after it lost an NLRB election in the overall plant group in February 2014. The micro-unit consists of only about 12 percent of the wall-to-wall bargaining unit that the UAW tried to represent in 2014.

After the UAW's "micro-victory," Volkswagen vowed to challenge the Board process and election results, and it appears to be doing so. On December 21, the UAW announced that it was filing an unfair labor practice charge against Volkswagen for refusing to bargain. It sounds as if Volkswagen may be intentionally engaging in a "technical refusal to bargain" as a tactic to get an "appeal" of the UAW victory. (The National Labor Relations Act does not contain a right of direct appeal in such a situation, so the typical way for an employer to be heard is to "draw" a charge of refusal to bargain.)

We expect the Board to rubber-stamp its Regional Director's actions in the election case and then for Volkswagen and the NLRB to file cross petitions for review and enforcement, respectively, in a federal appeals court. At this stage, Volkswagen's position has not been announced publicly, but we expect the company to argue that the micro-unit is inappropriate. This could be difficult: Volkswagen will probably have to convince a federal appeals court that the workers in the micro-unit share an overwhelming community of interest with the other plant workers.

German union sets up shop near Nashville, sets sights on Southerners and suppliers - Meanwhile, possibly smelling blood, the German labor organization IG Metall announced in November that it is establishing an office in Spring Hill, Tennessee, a suburb of Nashville that has a General Motors plant. IG Metall apparently plans to coordinate activities for organizing across the South with the UAW and to continue to push the idea of European-styled work councils. In a press statement, IG Metall noted that approximately 100,000 U.S. workers are employed by German auto companies, and that the vast majority in the South are not represented by a union. Both IG Metall and the UAW have said that auto workers in the South are not getting a fair share of the benefits of what the unions claim is an improved market for automobile manufacturers. Look for the UAW and IG Metall to continue the organizing efforts at Volkswagen and to attempt to establish a union presence among suppliers to Volkswagen and other automakers. The unions are expected to probe for weak links among suppliers, who may lack the resources, skill, experience, or will to counter the unions’ efforts to gain membership and bargaining rights.

NLRB panel majority finds unlawful Whole Foods’ policy prohibiting employees from secretly recording conversations - In a December 24 decision, a divided panel of the NLRB refused to accept the recommended decision of an administrative law judge and found that two of Whole Foods' policies restricting workplace recording by employees were unlawful. One policy prohibited workers from making video or audio recordings of meetings without approval of management or the consent of all parties to the conversation. The stated purpose of the policy was "... to encourage open communication, free exchange of ideas, spontaneous and honest dialogue and an atmosphere of trust." The second policy prohibited workers from recording conversations without management approval. Its stated purpose was "to eliminate a chilling effect on the expression of views that may exist when one person is concerned that his or her conversation with another is being secretly recorded. This concern can inhibit spontaneous and honest dialogue especially when sensitive or confidential matters are being discussed."

Despite the legitimate business purpose of each of the policies, the Board panel majority found that they interfered with employees' Section 7 rights under the NLRA and violated Section 8(a)(1). According to the Board panel majority (Board Chair Mark Gaston Pearce and Member Kent Hirozawa), the policies would reasonably be interpreted by employees to restrict protected activities such as "recording images of protected picketing, documenting unsafe workplace equipment or hazardous working conditions, documenting and publicizing discussions about terms and conditions of employment, documenting inconsistent application of employer rules, or recording evidence to preserve it for later use in administrative or judicial forums in employment-related actions." The panel majority found that the employer had no overriding interest for interfering with the employees' Section 7 activities and it emphasized that there were many situations where covert recordings were essential to protecting employees' Section 7 rights. The Board thus found that employees have a Section 7 right to make workplace audio/video recordings in some circumstances and that Whole Foods' prohibition on recordings was overbroad and unlawful. (Member Philip Miscimarra dissented.)

This is but one of many recent Board decisions finding that a common employer policy or workplace rule is unlawful under the current Board majority's expansive view of Section 7 rights and minimalist view of employer prerogatives. Whether the decisions generate positive or negative results for employees remains to be seen and is subject to debate. Many of the decisions seem simply to reinforce the current Board majority's view of the workplace as an adversarial environment and to attack legitimate employer policies intended to make the workplace more civil and productive, in the interest of both employers and employees.

THE GOOD, THE BAD AND THE UGLY

Is there an app for that? Well maybe not an app, but there sure is a website - Two former employees of the Service Employees International Union have created a website – coworker.org – that they say is intended to allow employees to gather, organize, and create change in their workplaces. According to Fast Company article, the website is currently hosting hundreds of initiatives for change in various workplaces. "We're codesigning new forms of collective advocacy power for workers which don't replace trade unions," co-creator Michelle Miller was quoted as saying. "They are actually new kinds of models that sit next to trade unions as options for workers to start to think about ways in which they want to have organizational power inside their workplaces."

One of the website’s activities was a "visible tattoo" campaign at Starbucks. Workers for the coffee chain posted a petition that the company allow workers to have visible tattoos. The petition was signed by 25,000 Starbucks workers in 17 countries, and may have been responsible for the coffee chain's revised dress code that now allows tattoos to be visible. There are reportedly more than 24 "live" petitions targeting various aspects of Starbucks employment, with about 10 percent of its workforce on the site. As we went to press, the website also contained a petition for the supermarket chain Publix to allow beards (more than 13,000 signatures), and for restaurant chain TGI Friday's to bring back automatic tipping for parties of six or more. (That one had barely more than 2,000 signatures – maybe wait staff realizes that "automatic" tips aren’t always as good as "voluntary" tips from satisfied diners.)

In any event, employers – especially those in the retail, hospitality and restaurant industries and those which have large numbers of geographically dispersed employees – will want to pay attention. If the website is successful, more such websites and apps are sure to follow.

IBEW, union-busting evil employer! - Connecticut-based Local 42 of the International Brotherhood of Electrical Workers employs clerical workers who belong to the American Federation of State, County, and Municipal Employees union. According to the clericals, who went on strike in November, the IBEW is anti-union and was acting badly – just like an employer. According to the president of the clerical workers' union, quoted in the Journal Inquirer, the IBEW "outsource[d] bargaining unit work to a non-union supervisor," and cut one employee's pay by $15.44 an hour. "I think it's a shame that Local 42 has decided to treat their employees in this way," the AFSCME local president was quoted as saying. "You can't claim to be an advocate for working people and, at the same time, seek to outsource work and significantly reduce your employees' pay." In the leadup to the strike, the clerical workers' union apparently filed an unfair labor practice charge against the IBEW, claiming "anti-union animus." Can that be right? Maybe these clericals would be happier working for a nicer employer – maybe one that isn't a union.

Restrictive work scheduling legislation begins to gain traction - As if there were not already enough seemingly well-intentioned but productivity damaging workplace laws and regulations, new work scheduling laws are being proposed at federal, state, and local levels. At the federal level, Sen. Elizabeth Warren (D-Mass.) in July 2015 introduced the Schedules That Work Act. The proposed legislation has little chance of success in a Republican-controlled Congress in 2016, but it is worth watching. Generally, the bill would require employers in the retail, food service, and cleaning industries (as well as others that may be designated by the Secretary of Labor) to provide each new hire with a written work schedule, including the minimum number of hours that the new hire will be assigned to work each month. If that initial schedule changed, the employer would be required to provide another written notification at least 14 days in advance of the date that the change would take effect. Among other things, the bill would also require minimum "reporting pay," which applies if an employee is scheduled to work a certain number of hours but is not actually given that amount of work after reporting; and extra pay for on-call time, split shifts, and schedule changes made on an "as needed" basis with less than 24 hours' notice.

Not to be outdone or willing to wait for federal legislation on the subject, a District of Columbia Councilmember on December 1, 2015, introduced the Hours and Scheduling Stability Act of 2015 in Washington. The proposed law, which would apply to retail employers with at least five locations across the country and to restaurant chains with 20 or more locations, would require covered employers to offer available work to current employees who are qualified before hiring new employees or using subcontractors. The announced intent of the proposal is to promote full-time work.

The D.C. proposal would also require employers to post schedules 21 days in advance of work and to pay workers up to four hours of pay if an employer changes a schedule. Schedule changes would have to be disclosed to the employee in advance, and a revised written schedule would have to be provided within 24 hours of the change. If an employer wants to add work time to an existing schedule, the employee may refuse the work. Any voluntary acceptance of added work by an employee would have to be in writing.

Employers should watch for more legislative proposals like these. In 2014, similar legislation became law in San Francisco despite vigorous opposition from local business groups, and comparable proposals are being considered elsewhere. The common thread in all the proposals is that they limit the ability of the employer and employee to negotiate on a full range of mutually advantageous arrangements and to agree on ones that could compensate the employee for flexibility in scheduling that some employers and employees desire.

 

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.

© Constangy, Brooks, Smith & Prophete, LLP | Attorney Advertising

Written by:

Constangy, Brooks, Smith & Prophete, LLP
Contact
more
less

Constangy, Brooks, Smith & Prophete, 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.