Google Prevails, In Part (And For Now), In Compensation Data Dispute With OFCCP

by Proskauer - Government Contractor Compliance & Regulatory Update
Contact

On July 14, 2017, an Administrative Law Judge (“ALJ”) for the Department of Labor issued a Recommended Decision and Order (the “Opinion”) in the case brought by the Office of Federal Contractor Compliance Programs (“OFCCP”) against Google over Google’s refusal to turn over certain employee data as part of a compliance audit.  The ALJ’s thorough opinion is informative, providing insights into OFCCP’s processes in compliance audits, basic canons of administrative and constitutional law, as well as the administrative proceedings that have garnered so much of the government contractor community’s attention.

Many of the commentators initially declared the decision a big “win” for Google and the government contractor community generally.  Although Google succeeded in part in its efforts to resist OFCCP’s invasive and burdensome data demands, its success in the proceeding was limited.  In the end, Google avoided only one (albeit a significant one) of OFCCP’s data requests.  Moreover, the Opinion does not preclude OFCCP from seeking that information again in the future.  Further, the record reflects that prior to these proceedings, Google produced significant quantities of data and documents to OFCCP at considerable cost and burden – by Google’s estimates the collection process cost $500,000 and took 2,300 person hours.  Although Google obtained some favorable rulings that contractors can use in their dealings with OFCCP, it is unclear whether this ruling will permit contractors to obtain significant relief from OFCCP’s demands in the future.

Background Of The Case

The case arose out of a traditional compliance evaluation of Google’s headquarters which commenced in 2015.  In response to its initial scheduling letter, OFCCP received from Google a snapshot of compensation data for over 21,000 employees, including data such as “gender, ‘race/ethnicity,’ hire date, job title, EEO-1 category (such as clerical or executive), job group, base salary or wage rate, hours worked in a typical workweek, and other compensation or adjustments to salary (bonuses, incentives, commissions, merit increases, locality pay, and overtime).”  After several follow up requests for information and data, the evaluation morphed into an onsite review that included interviews of more than 20 managers.

Following the interviews, OFCCP requested additional information, including the following categories of information for each of the employees in the establishment:

name, date of birth, bonus earned, bonus period covered, campus hire or industry hire …, whether the employee had a competing offer, current “CompaRatio,” current job code, current job family, current level, current manager, current organization, department hired into, education, equity adjustment, hiring manager, job history, locality, long-term incentive eligibility and grants, market reference point, market target, performance rating for past 3 years, prior experience, prior salary, referral bonus, salary history, short-term incentive eligibility and grants, starting CompaRatio, starting job code, starting job family, starting level, starting organization, starting position/title, starting salary, stock monetary value at award date, target bonus, and total cash compensation, and ‘any other factors related to Compensation.’

Google produced most of this information to OFCCP.  Then, OFCCP requested that Google again supplement its snapshot data to include the following additional categories of information:  “the employees’ ID, country of citizenship, secondary country of citizenship, visa (yes/no), visa type, and place of birth.”  Google produced this data as well.  All in, Google produced “844,560 compensation data points for the 21,114 employees on the snapshot.”  However, Google refused to comply with a number of the additional requests of OFCCP, including:

  1. “A “snapshot” as of September 1, 2014 – a year earlier than the first snapshot.”
  2. “A salary history (a list of starting salary and each salary change) and job history (a list of starting job and each change in job) for each person whom Google employed at its headquarters on either of the two snapshot dates. The histories must cover the entire time Google employed each person, going back for its longest-term employees to the founding of the corporation in 1998.”
  3. “The name, address, telephone number, and personal email of every employee reflected on either the 2014 snapshot or the 2015 snapshot.”

After Google refused to produce the requested information, OFCCP filed a complaint against Google to compel production.

The ALJ’s Rulings

After a hearing on the matter, the ALJ found that OFCCP’s request for an additional data snapshot from September 1, 2014 was reasonable.  OFCCP argued that “an additional snapshot is relevant because it will show whether the same indications of a possible adverse impact violation existed over time, not just on the single day reflected on the September 1, 2015 snapshot.”  After a detailed analysis, the ALJ found that OFCCP had provided sufficient evidence “to meet the deferential standard that applies in the narrow Fourth Amendment review appropriate to administrative subpoenas.”

In ruling that Google needed to provide the additional snapshot data, the ALJ found “no reason to question the relevance of most of the data categories that OFCCP requests Google include on the snapshot.”  He did, however, modify the required data fields slightly to exclude:  “place of birth, citizenship, and visa status,” “any other factors related to compensation” (because “OFCCP ha[d] withdrawn [its] request” for this information), “date of birth” and “locality information.”  The ALJ found these categories either irrelevant or unduly burdensome for Google.

With respect to the request for contact information for all employees at Google headquarters, the ALJ ruled that this request, as written, was unreasonable.  The ALJ seemed most concerned about the “extent to which the employee contact information, once at OFCCP, will be secure from hacking, OFCCP employee misuse, and similar potential intrusions or disclosures.”  He also raised questions about employee due process, as their information was being provided to the government without their knowledge and without their ability to opt out.  Based on these concerns, the ALJ ruled that after conducting more due diligence as to Google’s compensation procedures, OFCCP can request a list of 5,000 employee names and Google will provide the contact information for those employees.  This will allow OFCCP to determine which 100-300 employees it wishes to interview, without Google knowing the identities of these employees.  The ALJ also ruled that, if needed, OFCCP may request contact information for an additional 3,000 employees following the interviews of its first group of employees.

Finally, the ALJ denied “without prejudice” OFCCP’s request for historical compensation information going back to each employee’s hire date.  The ALJ reasoned that OFCCP had not sufficiently supported its need for the information to conduct its investigation.  He found that although OFCCP had identified disparities in Google’s compensation and had developed a theory as to the cause of those disparities, it had failed to take steps to investigate Google’s compensation practices to test its theory before demanding voluminous and burdensome compensation data.

For example, OFCCP supported its request by theorizing that Google’s alleged compensation disparities are the result of women being less effective negotiators than men at the time of hire.  However, the hearing record showed that Google generally does not negotiate compensation at the time of hire or promotion.  As such, OFCCP had failed to test its theory against Google’s actual practices before making its burdensome request.  Moreover, the support OFCCP offered for this theory – two media articles – were stricken from the record by the ALJ.

Even so, the ALJ invited OFCCP to request this information in the future “if it can show that the request is reasonable, within its authority, relevant to the investigation, focused, and not unduly burdensome.”  However, the ALJ ordered OFCCP to “offer to engage with Google in meaningful, good faith conciliation to resolve any dispute, including by showing why the information sought is reasonable, relevant, focused, and not unduly burdensome” prior to engaging in any further litigation.

Key Take Aways

Putting aside the specifics of the ALJ’s rulings, his thoughtful Opinion provides contractors with helpful guidance to use when under audit by OFCCP.

  • Signing a Government Contract Does Not Waive Contractors’ Fourth Amendment Rights. The ALJ forcefully rejected OFCCP’s argument that by signing a government contract with a provision permitting the government to access its records, Google had waived its Fourth Amendment rights in their entirety – deeming OFCCP’s position to be “without merit.”  As such, contractors can point to the Opinion if faced with overzealous compliance officers claiming they have an unfettered right to access contractor files.  Rather, such requests must be reasonable, relevant and material to the investigation and may not be too indefinite or broad.  To this end, the ALJ deemed requests for information concerning employees’ place of birth, citizenship or visa status irrelevant to matters within OFCCP’s authority.
  • OFCCP Must Be More Transparent. The ALJ emphasized that when Google first resisted OFCCP’s third effort to obtain these data, it demanded to know the issues OFCCP was investigating and “in what part of Google’s operations those issues arose.”  At that point, Google had provided extensive compensation data, and OFCCP had provided “no information about the issues it was finding, which prevented Google from evaluating whether OFCCP’s additional requests were relevant to the investigation.”  OFCCP refused to explain to Google its findings or its justification for its broad request.  Instead, it ordered Google to show cause why OFCCP should not bring an enforcement action.  “Google responded with an offer to continue producing certain information and discuss[] the parties’ disagreement,” and noted that OFCCP’s refusal to provide any explanation of the relevance of the information sought contravened its own regulations.  In response, OFCCP filed its administrative action against Google.  It was only during the administrative hearing that Google learned for the first time that OFCCP was investigating potential “systemic compensation disparities against women.”

Google’s experience unfortunately is not unusual.  Contractors participating in a compliance audit often are frustrated by OFCCP’s refusal to explain why its data requests are relevant to or to share even the most basic information about its investigations.  Contractors are often left with a difficult choice:  comply with what appear to be unreasonable and/or unfounded requests or challenge OFCCP and risk litigation.[1]  The Opinion makes clear that if OFCCP had provided information about its findings in its investigation, litigation could have been avoided.  Google had been very cooperative earlier in the investigation, and may have continued to provide information if OFCCP had provided the information necessary to assess the reasonableness of OFCCP’s requests.  In addition, the dialogue that may have ensued may have caused OFCCP to reconsider the scope of its requests.

With the Opinion, contractors now have a helpful resource upon which to rely when facing what appear to be unreasonable requests for information and compliance officers unwilling to provide information justifying the requests.

  • OFCCP Must Identify The Cause For Disparities That Exist And Must Tether Its Requests To That Cause. The ALJ noted that in requesting additional compensation information during its compliance evaluation, “OFCCP is on a search for the cause of a disparity it has found on a preliminary basis.”  The ALJ pointed to Directive 307 – “Procedures for Reviewing Contractor Compensation Systems and Practices” – as the standard OFCCP must follow to identify the cause of any pay disparities.  The ALJ found that “OFCCP should engage in an iterative process, asking Google for information, interviewing Google’s officials and managers, reviewing the documentary materials and data Google has produced, considering information gathered from the EEOC and the California Department of Fair Employment and Housing, and reviewing information from any other source it has.”  Following this, OFCCP “should consider Google’s statements of its policies and practices …,” “determine whether Google’s representations are consistent with the data and other information obtained,” and “then adjust its models and request further information consistent with observable indicators in the information it has.”

The ALJ found that, absent this process, “OFCCP’s requests for information are untethered to any factual basis and are no more than speculation.”  It is on this basis that the ALJ found OFCCP’s request for historical compensation data to be unreasonable.  The ALJ found that “OFCCP has not taken sufficient steps to learn how Google’s system works, identify actual policies and practices that might cause the disparity, and then craft focused requests for information that bears on these identified potential causes,” resulting in the requests being “unreasonable: unfocused, irrelevant, and unduly burdensome.”

Based on this analysis, when faced with additional compensation data requests by OFCCP, contractors should press the agency to identify and justify the specific practice it believes caused the disparity.  This will allow contractors to engage in a dialogue with OFCCP regarding this claimed practice and to determine whether OFCCP has undertaken all of the steps specified in Directive 307 before it demands the production of additional data supporting its claim.  Contractors should point to this decision as support for the notion that contractors need not merely acquiesce to unreasonable demands from OFCCP until it undertakes the steps specified in the Directive and then provides additional information to support the justification for its requests.

[1] Proskauer’s approach to representing clients in OFCCP’s audits aims to avoid such circumstances by developing a good rapport with OFCCP compliance officers so when disputes arise they can usually be negotiated to a mutually-satisfactory resolution.

[View source.]

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.

© Proskauer - Government Contractor Compliance & Regulatory Update | Attorney Advertising

Written by:

Proskauer - Government Contractor Compliance & Regulatory Update
Contact
more
less

Proskauer - Government Contractor Compliance & Regulatory Update 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.