The Omnibus Final HIPAA Rule Is Here

by Pepper Hamilton LLP
Contact

On January 17, 2013, the Office of Civil Rights of the U.S. Department of Health and Human Services (HHS) announced the omnibus final rulemaking (Omnibus Rule). According to HHS, this Omnibus Rule is needed to strengthen privacy and security protections established under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) for individuals’ information maintained in electronic health records and other formats.

The much-anticipated and long-awaited Omnibus Rule is 563 pages long and covers many topics, issues and concerns that have emerged during the 15-plus years since the passage of HIPAA and the implementing privacy, security and enforcement regulations, and the nearly four years since the passage of the Health Information Technology for Economic and Clinical Health (HITECH) Act in February 2009. Throughout the Omnibus Rule, HHS responds to public comments submitted under the various prior proposed rulemakings and notes that it will be providing additional guidance on certain topics.

In addition to providing a brief overview of the Omnibus Rule, this Alert highlights some of the modifications directly impacting business associates and key changes to the breach notification rule.

Overview of the Omnibus Rule

The Omnibus Rule actually is comprised of the following four final rules. HHS decided to combine these rules in an effort to reduce the impact on regulated entities and to reduce the number of times regulated entities would need to undertake certain compliance activities.

  1. Final modifications to the HIPAA Privacy, Security, and Enforcement Rules mandated by the HITECH Act, and certain other modifications to improve the Rules, which were issued as a proposed rule on July 14, 2010. These modifications include:

    • making business associates of covered entities directly liable for compliance with certain of the HIPAA Privacy and Security Rules’ requirements

    • strengthening the limitations on the use and disclosure of protected health information (PHI) for marketing and fundraising purposes

    • prohibiting the sale of PHI without individual authorization

    • expanding individuals’ rights to receive electronic copies of their health information and to restrict disclosures to a health plan concerning treatment for which the individual has paid in full out-of-pocket

    • requiring modifications to, and redistribution of, a covered entity’s notice of privacy practices

    • modifying the individual authorization and other requirements to facilitate research and disclosure of child immunization proof to schools, and to enable access to decedent information by family members or others

    • adopting the additional HITECH Act enhancements to the Enforcement Rule not previously adopted in the October 30, 2009 interim final rule, such as the provisions addressing enforcement of noncompliance with the HIPAA Rules due to willful neglect.

  2. Final rule adopting changes to the HIPAA Enforcement Rule to incorporate the increased and tiered civil money penalty structure provided by the HITECH Act, originally published as an interim final rule on October 30, 2009.
  3. Final rule on Breach Notification for Unsecured PHI under the HITECH Act, which replaces the breach notification rule’s “harm” threshold with a more objective standard and supplants an interim final rule published on August 24, 2009.
  4. Final rule modifying the HIPAA Privacy Rule as required by the Genetic Information Nondiscrimination Act (GINA) to prohibit most health plans from using or disclosing genetic information for underwriting purposes, which was published as a proposed rule on October 7, 2009.

Despite the breadth of the Omnibus Rule, there remain some anticipated rules from HHS implementing the HITECH Act requirements. In particular, the Omnibus Rule does not address the proposed rulemaking for the accounting of disclosures requirement under the HITECH Act, which was the subject of a May 2011 notice of proposed rulemaking.

Timing

The Omnibus Rule will be effective 60 days after publication in the Federal Register – on March 26, 2013. In general, covered entities and business associates must comply with the requirements of the Omnibus Rule 180 days after the effective date of the rules – by September 23, 2013.

There are two notable exceptions to this timeline. First, for those business associate agreements that qualify for the transition exception, the parties will have until the earlier of (1) the date the existing agreement is renewed or modified, or (2) September 22, 2014, to bring their agreements into compliance. Second, with respect to compliance with the notification requirements for breaches of unsecured PHI, the standards provided in the interim final rule continue to apply until the compliance date for the Omnibus Rule of September 23, 2013.

Business Associates and Business Associate Agreements

The Omnibus Rule finalizes rules directly impacting business associates of covered entities, and subcontractors to business associates. Under the HIPAA Privacy Rule, business associates (and by extension subcontractors) are permitted to use and disclose PHI only in accordance with their business associate contracts or as required by law.

Who Is a Business Associate?

Addressing the pivotal question of “who is a business associate,” the Omnibus Rule makes a number of modifications to the existing definition of “business associate.” HHS has added the word “maintains” to the definition to clarify that entities that store or maintain PHI are business associates. Generally, a business associate includes a person (or entity) who creates, receives, maintains or transmits PHI on behalf of a covered entity (emphasis added). Additionally, the definition now includes the HITECH Act-mandated specific inclusion of:

  • Health Information Organization, E-prescribing Gateway, or other person that provides data transmission services with respect to PHI to a covered entity and that requires access on a routine basis to such PHI, and
  • a person that offers a personal health record to one or more individuals on behalf of a covered entity.

Additionally, through the Omnibus Rule HHS finalized its proposal to extend the HIPAA rules to subcontractors. Subcontractors are specifically included right in the modified definition of “business associate.”

A subcontractor that creates, receives, maintains, or transmits PHI on behalf of the business associate. (A subcontractor is now defined as a person to whom a business associate delegates a function, activity, or service, other than in the capacity of a member of the workforce of such business associate.)

In adopting its proposal, HHS maintains that it has authority to do so under the HITECH Act and notes that the intent of this extension of the rules was to “avoid having privacy and security protections for protected health information lapse merely because a function is performed by an entity that is a subcontractor rather than an entity with a direct relationship with a covered entity.” HHS clarifies that this extension of the rules is not limited to “first tier” subcontractors but also applies to downstream contractors that create, receive, maintain or transmit PHI for or on behalf of business associates or subcontractors.

Direct Liability of Business Associates and Subcontractors

With the final adoption of these changes, business associates and subcontractors are directly liable for violations of applicable HIPAA privacy, security and breach notification rules, including:

  • compliance with the HIPAA Security Rule’s administrative, physical and technical safeguards and certain documentation requirements
  • impermissible uses and disclosures of PHI and certain other requirements under the Privacy Rule, including providing an accounting of disclosures of PHI and failing to disclose PHI as needed to respond to an individual’s request for an copy of electronic PHI
  • notification of a covered entity of a breach of unsecured PHI
  • compliance with documentation requirements including executing business associate agreements
  • failing to disclose PHI when required by the Secretary of HHS to determine the business associate’s compliance.

This direct liability is in addition to contractual liability under business associate agreements. In discussing the modifications to the Security Rule requirements, HHS notes that as business associates, and their subcontractors, are already contractually obligated to comply with these requirements, compliance will only require “modest improvements.” HHS does also recognize, however, that some business associates may not have engaged in the formal administrative safeguards such as performing the risk analysis. Notwithstanding HHS’s view of the size of the task ahead, coming into compliance with the HIPAA Rules will be a significant undertaking for business associates and business associate subcontractors who will need to conduct, or revisit, their risk analysis and develop and implement a HIPAA compliance program.

Business Associate Agreements

Covered entities and business associates are required to obtain “satisfactory assurances” through execution of business associate agreements with their business associates and subcontractor business associates. The Omnibus Rule includes modifications to the requirements for business associate agreements, both within the Privacy Rule and within the Security Rule. One such change clarifies that the obligation to obtain satisfactory assurances from a business associate that is a subcontractor is the obligation of the business associate and not an obligation of the covered entity. Another provision imposes the obligation on a business associate that is aware of non-compliance by a subcontractor to respond as a covered entity would be required to, including terminating the agreement if necessary. Despite receiving many comments questioning the continued need for business associate agreements, HHS declined to eliminate the requirement and states that they continue to see a need for business associate agreements.

HHS discusses and confirms that both covered entities and business associates are liable for the violations due to the acts or omissions of their agents, under the federal common law standard of agency. Not all business associates are automatically agents of covered entities and not all subcontractors are agents of covered entities. Such liability depends on whether there is an agency relationship and whether the act or omission was within the scope of the agency.

Changes to Breach Notification Rule

One of the most significant developments in the Omnibus Rule is HHS’s change in the definition of what constitutes a breach. Under the 2009 interim final Breach Notification Rule for Unsecured PHI (Interim Rule), a breach required a finding that the access, use or disclosure of PHI poses “a significant risk of financial, reputational or other harm to an individual.” This harm threshold, which had to be met before breach notification was triggered, has always been controversial. The Omnibus Rule replaces the “harm threshold” with a new standard, which will likely result in more breach notifications to patients.

Under the Omnibus Rule, the breach is presumed upon the occurrence of an impermissible acquisition, access, use or disclosure of PHI such that notification is required unless a risk assessment demonstrates that there is a low probability that the PHI has been compromised.

Four factors to be considered in conducting the risk assessment are:

  • the nature and extent of the PHI involved (such as types of identifiers and risk of re-identification)
  • the unauthorized person who used the PHI or to whom the disclosure was made
  • whether the PHI actually was acquired or viewed, and
  • the extent to which the risk to the PHI has been mitigated.

Additionally, HHS removed the exception on limited data sets that do not contain any dates of birth and zip codes. Thus, the breach standard and risk assessment apply to limited data sets as well.

Other provisions of the Interim Rule related to breach notification largely remain unchanged. However, the Omnibus Rule did clarify that notice to HHS for breaches affecting less than 500 individuals should be no later than 60 days after the end of the calendar year in which the breaches were discovered, not in which the breaches occurred.

In summary, the Omnibus Rule has set the default position in a security incident involving PHI as sending breach notifications unless there is some showing of low probability that PHI has been compromised. In HHS’s opinion, this focus on whether the PHI (not the individual) has been harmed is a more objective standard. Questions still will arise since the Omnibus Rule has not defined what “compromised” means. HHS encourages covered entities and business associates to take advantage of the safe harbor by encrypting PHI thus avoiding this issue altogether.

No Time to Delay

With the publication of the Omnibus Rule, it is clear that health care providers, other HIPAA-covered entities, business associates and business associate subcontractors all will need to re-invest in HIPAA/HITECH Act compliance efforts in 2013. These tasks will include conducting (or updating) risk analysis, risk management activities, policy and procedure implementation or updates, and reviewing and amending or executing business associate contracts with business associates and subcontractors. With the limited time to come into compliance afforded by the Omnibus Rule, combined with HHS’s increasing emphasis on enforcement, these efforts will require committed investment of both resources and funds.

The final rulemaking is to be published in the Federal Register on January 25, 2013, and until then the pre-publication rulemaking is available at https://www.federalregister.gov/public-inspection.

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.

© Pepper Hamilton LLP | Attorney Advertising

Written by:

Pepper Hamilton LLP
Contact
more
less

Pepper Hamilton 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.