New Jersey Department of Labor Proposes Regulations Implementing Sick and Safe Leave Law

by Epstein Becker & Green

Epstein Becker & Green

On September 13, 2018, the New Jersey Department of Labor and Workforce Development (“NJ DOL”) issued proposed regulations to implement the state’s new paid sick and safe leave (“sick leave”) law—P.L. 2018, c. 10 (“Act”). The proposed regulations have a 60-day public comment period, which may be extended. Therefore, the final regulations will not be adopted before 2019. The Act, which was the subject of a previous Act Now Advisory, becomes effective October 29, 2018. In sum, the Act requires all employers to provide paid sick leave to their New Jersey employees. With limited exception, the Act entitles part-time and full-time employees, whether regular, temporary, or seasonal, to sick leave.

The proposed regulations generally track the provisions of the Act and address how sick leave must be accrued, used, paid, paid out, and carried over from year to year. In addition, the proposed regulations echo the Act’s notification and recordkeeping requirements, as well as its prohibitions against retaliation and discrimination. The regulations, like the Act, incorporate the state’s Wage and Hour Law with regard to penalties and the administrative procedures for addressing alleged violations.

Paid Time Off (“PTO”)

The proposed regulations confirm that employers that already provide employees with PTO will be in compliance with the Act as long as the employer’s PTO program (e.g., sick, vacation, and personal days) meets all of the requirements of the Act and the proposed regulations, including as to accrual or frontloading, permitted use, payment, payout, and carryover of earned sick leave. As the below summary indicates, however, the revision and updating of existing PTO policies will likely be necessary to meet this standard.

Benefit Year

The Act requires employers to provide employees with up to 40 hours of paid sick leave per benefit year. A benefit year may be the calendar year, or another set 12-month period. The proposed regulations state that employers must apply the same benefit to all of its employees. Once a benefit year has been established by the employer, it cannot be changed without providing detailed information in a notice to the NJ DOL Commissioner at least 30 days in advance. If the Commissioner determines that the proposed change would prevent the accrual or use of earned sick leave by an employee, the Commissioner may deny the change and impose a benefit year on the employer.

“Foreseeable” Leave and Barring Use of Leave on “Certain Dates”

The Act permits employers to require up to seven calendar days’ notice of the need to use sick leave if the need for leave is “foreseeable.” In addition, under the Act, employers may prohibit employees from using foreseeable earned sick leave on “certain dates” and require reasonable documentation if sick leave that is not foreseeable is used during those dates.

Under the proposed regulations, the need for leave would be considered “‘foreseeable’ when the employee is able to predict or know in advance that he or she will need to use earned sick leave, such as a scheduled doctor’s visit, regularly occurring medical treatment or regularly scheduled therapy appointment.” For foreseeable leave, employees would be required to make a reasonable effort to schedule the time off “in a manner that does not unduly disrupt the operations of the employer.”

Under the proposed regulations, the “certain dates” on which an employer may prohibit employees’ use of foreseeable leave or require documentation of the need for leave would be limited to “verifiable high-volume periods or special events” where the use of sick leave would unduly disrupt the employer’s operations. The proposed regulations give as an example of a “high-volume period,” for an airline industry employer, the days in and around Thanksgiving. An example of a “special event” is, for a manufacturer of retail products, the day or week of a product launch. The proposed regulations would require employers to provide reasonable notice to employees of such “certain dates.”

Accruing or Advancing Sick Leave

The Act requires employers to provide up to 40 hours of earned sick leave to employees per benefit year. Employers may (i) use an accrual method under which employees earn one hour of sick leave per 30 hours worked, up to 40 hours, or (ii) advance, or frontload, the entire 40 hours at the beginning of the benefit year. Accrual for current employees must begin October 29, 2018, i.e., the effective date.

Payout and Carryover

The proposed regulations detail the payout and carryover requirements of the Act with respect to leave that accrues and leave that is frontloaded. According to the proposed regulations, the following would apply to a payout and to carryover when the employer follows the accrual methodology:

  1. In the final month of the employer’s benefit year, the employer may provide an offer to an employee for payout of unused earned sick leave.
  2. The employee may accept the employer’s payout offer within 10 calendar days from the date the offer was made.
  3. If the employee does not accept the payout offer within 10 calendar days from the date of the employer’s offer, the employee is deemed to have declined the employer’s offer.
  4. If the employee agrees to receive a payout, the employee shall choose either a payout for the full amount of unused earned sick leave or for 50 percent of the amount of unused earned sick leave.
  5. If the employee declines a payout of unused earned sick leave or agrees to a payout of 50 percent of the amount of unused earned sick leave, the employee shall be entitled to carry forward to the following benefit year any unused earned sick leave, except that the employer shall not be required to permit the employee to carry forward from one benefit year to the next, more than 40 hours of earned sick leave.
  6. If the employee agrees to a payout of the full amount of unused earned sick leave, the employee shall not be entitled to carry forward to the following benefit year any unused earned sick leave.
  7. The payout amount shall be based on the rate of pay that the employee is earning at the time of the payout.

The following would apply to a payout and to carryover when the employer frontloads leave:

  1. In the final month of the employer’s benefit year, the employer shall either provide to the employee a payout for the full amount of unused earned sick leave or permit the employee to carry-over any unused earned sick leave, except that the employer shall not be required to permit the employee to carry forward from one benefit year to the next, more than 40 hours of earned sick leave.
  2. If the employer provides to the employee a payout for the full amount of unused earned sick leave, the employer may not use the accrual method with respect to that employee during the next benefit year.

Consistent with the Act, the proposed regulations state that employees are not entitled to a payout of unused earned sick leave upon separation of employment.

Sick Leave Payment Amount

The proposed rules for determining the required amount of payment for leave appear to have the potential for obligating employers to pay employees more when they use sick leave than when they take other PTO, and may exceed what the Act appears to require.

Although the Act is silent with respect to bonuses, the proposed regulations appear to require nondiscretionary bonuses to be included in determining an employee’s rate of pay for sick leave purposes by stating, “Where an amount of a bonus is wholly within the discretion of the employer, the employer is not required to include the bonus when determining the employee’s rate of pay for earned sick leave purposes.” Since many bonuses are not determined until the end of the year, this rule has the potential for requiring employers to make end-of-year adjustments.

In addition, the Act states that employers must pay earned sick leave “at the same rate of pay with the same benefits as the employee normally earns, except that the rate of pay shall not be less than the minimum wage required for the employee pursuant to … N.J.S.A. 34:11-56a4.” That statutory provision establishes the minimum wage rate and overtime rate, and also includes exceptions to them (e.g., colleges may pay full-time students 85 percent of minimum wage). The proposed regulations, however, go on to state that “[u]nder no circumstances during a period of earned sick leave may an employer pay an employee less than the State minimum wage rate.” The rule, as proposed, thus appears to be inconsistent with regard to the rate at which sub-minimum wage earners should be paid for sick leave. 

Non-Retaliation and No-Fault Attendance Policies

The proposed regulations reiterate and amplify the Act’s prohibition of retaliatory action against employees who take leave provided by the Act. The proposed regulations would prohibit employers from counting the “legitimate” use of earned sick leave as an absence that could subject the employee to “discipline, discharge, demotion, suspension, loss or reduction of pay or another adverse action.” The proposed regulations go on to confirm that this prohibition includes “‘no fault’ attendance policies, whereby an employee receives a point or demerit for any absence no matter what the reason, and are subject to discipline or are foreclosed from a promotional opportunity(ies) after the accumulation of a certain number of points….” The proposed regulations would not, however, prevent employers from disqualifying employees who take leave under the Act from receiving perfect attendance bonuses. As such, the proposed regulations track and are consistent with the Family and Medical Leave Act.

Recordkeeping, Exempt Employees, and Maintenance of Records

The proposed regulations expand upon the recordkeeping requirements contained in the Act and, in one important respect, offer a helpful clarification with respect to recordkeeping requirements as to exempt employees. The proposed regulations would require employers to retain, for five years, records documenting as to each employee: (i) hours worked, (ii) the amount of leave accrued or advanced, (iii) the amount of leave used, (iv) the amount paid to the employee for leave taken, and (v) the amount of leave paid out and carried over.

The Act includes the requirement that employers document hours worked by employees. The requirement does not distinguish between nonexempt employees—whose hours should be documented for wage and hour compliance—and exempt employees, for whom employers need not normally count number of hours worked. The proposed regulations address this conundrum by permitting employers to “[p]resume, solely for the purpose of calculating earned sick leave accrual, that the [exempt] employee works 40 hours per week.”

Required Notices

The proposed regulations, like the Act, require employers to post a notice that will be prepared by the NJ DOL summarizing the Act. The proposed regulations confirm that the notice will be made available on the NJ DOL’s website and further states that the posting requirement may be satisfied by posting the notice on an employer’s Internet site or intranet site if that site is for the exclusive use of employees and all employees have access.

In addition, employers must provide each employee with a copy of the notice: (i) within 30 days of its issuance, and thereafter (ii) upon hire and (iii) upon the first request of an employee. The proposed regulations would permit distribution by email.

Independent Contactors

Of interest, the proposed regulations contain a provision expressly addressing independent contractors and stating that the “ABC test” will apply in determining whether an individual is an independent contractor or an employee. As we recently discussed in a previous Act Now Advisory, New Jersey is turning up the heat on employers that misclassify employees as independent contractors, in an apparent effort to, among other things, increase state revenues. The potentially stiff penalties for failing to provide paid sick leave in accordance with the Act, as well as for other violations, is further indication that the state is continuing to heighten the risks and exposure arising from the failure to strictly comply with the ABC test when classifying workers as independent contractors.

Collective Bargaining Agreements (“CBAs”)

CBAs are exempted from the Act, to an extent. The proposed regulations confirm that, until a CBA expires, the Act does not apply to employees who, as of the October 29, 2018, effective date, are covered by the CBA. Moreover, employees or their representatives may waive rights under the Act during negotiations of a CBA.

Proposed Regulations’ Comment Period

The NJ DOL will conduct a public hearing on the proposed regulations on November 13, 2018, at the NJ DOL’s offices in Trenton. In addition, written comments may be submitted by December 14, 2018, to David Fish, Executive Director of DOL’s Office of Legal and Regulatory Affairs.

What New Jersey Employers Should Do Now 

  • Request an opportunity to speak at the November 13, 2018, hearing or submit written comments, if you have comments, objections, or suggestions with respect to the proposed regulations.
  • Determine whether you will follow the accrual or frontloading methodology.
  • Establish recordkeeping procedures that comply with the Act and proposed regulations.
  • Prepare or revise PTO policies to ensure compliance with the Act and proposed regulations. Make sure such policies explain:
    • the benefit year (i.e., the calendar year or another 12-month period);
    • whether sick leave accrues or is advanced;
    • the waiting period for the use of leave, if any (up to 120 days is permitted);
    • the procedures for requesting leave in advance and when leave is unforeseeable, including notification and documentation requirements and “certain dates” on which foreseeable leave may be prohibited;
    • the carryover and payout of unused leave, including at the time of separation from employment;
    • if applicable, that employees who exhaust PTO or paid vacation time will not be entitled to additional paid sick leave; and
    • that employees will not be retaliated against for utilizing paid sick leave.
  • Provide training to management, payroll, and human resources staff on the requirements of the Act and proposed regulations.
  • Upon the NJ DOL’s issuance of its sick leave notice, be prepared to:
    • post it on the company’s intranet or a dedicated employee Internet site;
    • post it with the company’s other employment notices (i.e., in a conspicuous place at each of your work places);
    • distribute it to all employees in hard copy or by email;
    • provide it to all new employees upon hire; and
    • provide it to any employee upon request.
  • Review independent contractor arrangements to confirm that such individuals are properly classified.

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.

© Epstein Becker & Green | Attorney Advertising

Written by:

Epstein Becker & Green

Epstein Becker & Green 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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.