Preparing For Philadelphia’s Fair Workweek Employment Ordinance

Fox Rothschild LLP
Contact

Fox Rothschild LLP

In a growing trend among major cities, Philadelphia has enacted a law that will impose stringent new scheduling and workplace management practices on hospitality industry and retail employers with more than 250 employees and certain other criteria. Businesses affected by the law should expect significant documentation and compliance obligations.

The Fair Workweek Employment Ordinance, which goes into effect on January 1, 2020, mandates that employers provide non-exempt employees with:

  • Advance notice of their schedules
  • "Predictability Pay” when there is a deviation from provided schedules
  • “Good faith estimates” of anticipated schedules

It also requires that current employees be offered available shifts prior to hiring outside the organization.

Philadelphia City Council passed the Fair Workweek Employment Standards Ordinance in December 2018, becoming the fifth major city to impose similar predictive scheduling requirements on retail or hospitality employers. Similar laws have been passed in San Francisco, New York, Seattle and Washington, DC. Failure to comply with these scheduling and workplace management practices can result in significant fines and penalties.

Covered Employers

Under the ordinance, the term "Covered Employers” is defined to include full-service restaurants, limited-service restaurants, food services contractors, caterers, mobile food service providers, drinking places (i.e., bars, pubs and lounges), cafeterias, buffets, snack and nonalcoholic beverage bars, hotels, motor hotels, resort hotels, motels and retail businesses; provided such establishments employ 250 or more employees and have 30 or more locations worldwide (including chain establishments or franchises associated with a franchisor or network of franchises that employ more than 250 employees in the aggregate).

Advance Notice

New Hires

At the time of hire, Covered Employers are required to provide employees with a written, good faith estimate of the employee’s work schedule, which must include:

  • the average number of work hours the employee can expect to work in each week over a typical 90-day period;
  • whether the employee can expect to work any on-call shifts; and
  • a subset of days and times or shifts that the employee can typically expect to work, or days of the week and times or shifts on which the employee will not be scheduled to work.

Covered Employers shall revise the good faith estimate when there is a significant change to an employee’s work schedule due to the employee’s availability or the employer’s business needs. The Ordinance does not define when “a significant change to an employee’s work schedule” occurs. The Covered Employer is also required to provide the new employee with a written work schedule that runs through the last date of the currently posted schedule.

Existing Employees

Covered Employers must provide written notice of the work schedule to all employees in a conspicuous and accessible location where employee notices are customarily posted. If the employer posts the schedule electronically, all employees must have access to it on-site. From January 1, 2020 through December 31, 2020, work schedules shall be posted no later than 10 days before the first day of any new schedule. Beginning January 1, 2021, Covered Employers are required to post the work schedule no later than 14 days before the first day of any new schedule.

Covered Employers are required to provide notice of any proposed changes to the work schedule as promptly as possible and prior to the change taking effect. The written work schedule must be revised to reflect any change within 24 hours of making the change. An employee may decline to work any hours or additional shifts not included in the originally posted work schedule. If an employee voluntarily consents to work hours or shifts not included in the posted work schedule, such consent must be in writing.

All employees are permitted to make requests to change their work schedules. However, Covered Employers are not obligated to grant these requests.

Compensation for Changed Work Schedules

If a Covered Employer makes a schedule change after the required advance notice period, the employee will be entitled to “Predictability Pay,” in addition to the employee’s regular pay for hours actually worked by the employee, as follows:

  • One hour of Predictability Pay at the employee’s customary rate of pay, when a Covered Employer adds time to a work shift or changes the date or time or location of a work shift, with no loss of hours.
  • Predictability Pay calculated as no less than one-half times the employee’s customary rate of pay per hour for any scheduled hours the employee does not work, when a regular or on-call shift is cancelled or shortened.

Employees are not entitled to Predictability Pay in the following circumstances:

  • An employee makes a written request to change his/her schedule;
  • A schedule change is the result of voluntary shift trades or coverage arrangements, subject to any employer policy regarding required conditions for employees to exchange shifts;
  • Unforeseen/emergency situations such as threats to an employee’s or a Covered Employer’s property, failure of a public utility, shutdown of public transportation, fire, flood or other natural disaster, a state of emergency declared by the appropriate authorities, severe weather conditions that disrupt transportation or pose a threat to employee safety;
  • An employee begins or ends work no more than 20 minutes before or after the scheduled start or end time of the shift;
  • An employee volunteers to work additional hours in response to a mass written communication (that makes clear that accepting such hours is voluntary) from a Covered Employer about the availability of additional hours as a result of another employee being unable to work scheduled hours;
  • There is a reduction of hours due to termination of employment of the individual;
  • There is a reduction of hours due to disciplinary suspension, provided the incident leading to the disciplinary action is in writing;
  • The posted work schedule is changed within 24 hours of providing a new hire with the written work schedule;
  • A ticketed event is cancelled, scheduled, rescheduled, postponed, delayed, increases in expected attendance by 20% or more, or increases in duration, due to circumstances outside a Covered Employer’s control and that occur after the work schedule has been posted; or
  • A hotel banquet event is scheduled, due to circumstances that are outside a Covered Employer’s control, after the work schedule has been posted.

Right to Rest Between Work Shifts

Employees are permitted to decline, without penalty, any work hours that are scheduled or occur within nine hours of the end of the previous day’s shift or a shift that spanned two days. An employee may consent to work such shifts, so long as the consent is in writing. If an employee consents in writing, the Covered Employer shall compensate the employee an additional $40 for each such shift. Employees are permitted to revoke their consent to work such shifts, in writing, at any time during their tenure. The Ordinance is unclear as to whether an employer can obtain a blanket authorization from an employee to work such shifts or whether the employee can revoke such authorization mid-shift.

Offer of Work to Existing Employees

Under the Ordinance, Covered Employers are required to offer work shifts to existing employees before hiring new employees or engaging subcontractors. Covered Employers must provide written notice of available work shifts for at least 72 hours, unless a shorter period is necessary to timely perform the work. The notice must be in English and in the primary language(s) of the employees at the workplace. The notice must be posted both in a conspicuous location at the workplace that is readily accessible and visible to all employees and electronically, if that is the method normally used for distributing scheduling information. The notice must include:

  • a description of the position and its required qualifications;
  • the schedule of available shifts;
  • the length of time for which coverage is needed; and
  • the process for notifying the Covered Employer of their desire to work the offered shifts.

Covered Employers are permitted to provide the notice concurrently to employees at the location where the shifts will be worked, locations other than the location where the work is to be performed, and to external candidates.

The Ordinance specifically states that Covered Employers are not required to “offer employees work hours paid at a premium rate under state or federal law.” The plain language of the Ordinance suggests that a Covered Employer would not have to offer available shifts to existing employees if filling such shifts with an existing employee from any location would require a Covered Employer to pay the employee overtime.

Assignment of Available Shifts

In the event that one or more employees accept such shifts, the shifts shall first be distributed to qualified employees who regularly work at the location where the shifts are available. If it is the regular practice of a Covered Employer to schedule employees across multiple locations, shifts must then be distributed to qualified employees who work at other locations. If it is not a Covered Employer’s regular practice to schedule employees across multiple locations, offering the available shifts to employees at a different location is optional. Covered Employers are prohibited from distributing hours in a way that discriminates against employees or is intended to avoid application of the Patient Protection and Affordable Care Act.

Covered Employers may hire new employees for the available work shifts if:

  • an existing employee does not accept the offer of available work shifts within 24 hours after the 72 hour posting period ends;
  • it receives written confirmation from eligible employees that they are not interested in accepting the available work shifts; or
  • existing employees have only accepted a subset of the offered work shifts and there are remaining shifts available.

Presumption of Retaliation

The Ordinance prohibits retaliation against an employee who exercises his/her rights under the Ordinance. In addition, the Ordinance creates a “rebuttable presumption” of retaliation if an employee is subjected to an adverse action within 90 calendar days of the employee’s exercise of rights under the Ordinance. There is no “rebuttable presumption” of retaliation, however, if the adverse action was for just cause and the incident that led to the adverse action was documented in writing. For seasonal employees, a “rebuttable presumption” of retaliation applies if the individual’s employment ended before the 90 calendar day period expired and the Covered Employer fails to rehire the individual to work in the same position at the next opportunity for work.

Notice Requirements

At the time of hire and within 24 hours of any change, Covered Employers must advise employees, in writing, of its policy for offering and distributing work shifts. The policy must also be posted in an accessible location in the workplace and include:

  • where employees can access written notices of available work shifts;
  • how employees may notify the Covered Employer of their desire to work the available shifts; and
  • the factors the Covered Employer considers when assigning work shifts among qualified and interested employees.

Additionally, Covered Employers are required to post a notice, to be prepared by the City, summarizing the rights and responsibilities under the Ordinance. The notice must be posted in a conspicuous and accessible location where employee notices are customarily posted

Recordkeeping Requirements

Covered Employers are required to maintain records that demonstrate compliance with the Ordinance for a period of two years. Records that must be maintained include, but are not limited to good faith estimates of work schedules and any modifications thereto, written consent for work shifts, offers of work shifts to existing employees and responses to those offers, and payroll records showing Predictability Pay. Covered Employers must grant access to these records to the City upon request, with appropriate notice and at a mutually agreeable time. Upon request by an employee, and in accordance with the rules to be established by the City, Covered Employers must provide the employee with work schedules for all employees at the location in writing for any previous week for the past two years, including the originally posted and modified versions of work schedules.

Enforcement

Aggrieved individuals have two avenues to assert their rights under the Ordinance. First, they can file a claim in court within two years of the alleged violation. Second, they can file a claim within two years of the date the employee knew or should have known of the alleged violation with an agency designated by the Mayor (the Agency) that will be responsible for administering and enforcing the Ordinance. If a court or the Agency determines that the Covered Employer has violated the Ordinance, the successful plaintiff/complainant can receive full restitution for lost wages and benefits (including Predictability Pay), reinstatement (if the individual’s employment was terminated in violation of the Ordinance’s anti-retaliation provisions), attorneys’ fees, and costs. Aggrieved individuals who prevail in court can obtain liquidated damages of up to $2,000. If an aggrieved individual files a complaint with the Agency and the Agency determines that a Covered Employer violated the Ordinance, the City could assess fines of $2,000 for violation of the anti-retaliation provision and $1,000 for all other violations.

It is evident that this Ordinance will impose significant administrative burdens, including rigorous documentation obligations, on Covered Employers. Covered Employers need to ensure that their practices of posting schedules and offering shifts to existing employees comply in all respects with the Ordinance. Covered Employers should work closely with experienced employment counsel well in advance of January 1, 2020 to ensure compliance with the Fair Workweek Employment Standards Ordinance.

[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.

© Fox Rothschild LLP | Attorney Advertising

Written by:

Fox Rothschild LLP
Contact
more
less

Fox Rothschild 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.