UK HR Two Minute Monthly: covert surveillance; holiday carry over; sexual orientation discrimination; interim relief

Bryan Cave Leighton Paisner
Contact

Summary

Our December 2019 update outlines the key UK employment law developments over the last month. It includes cases on covert surveillance, sexual orientation discrimination when there is no identifiable victim, harassment under the Protection from Harassment Act 1997, the doctrine of state immunity as it applies to British civilians working in the UK for a foreign state, the test for interim relief in whistleblowing claims and the latest ECJ decision on holiday carry over in sickness absence cases. We also outline other points of note, including the Government’s response to the Women and Equalities Committee report into the use of NDAs in discrimination cases and an independent review of the international evidence on the impact of minimum wages.

Covert CCTV surveillance to monitor workplace theft was not an infringement of employees’ right to privacy under Article 8 ECHR

The European Court of Human Rights has held that the Spanish courts did not fail to protect the Article 8 ECHR rights of employees when they upheld their dismissals based on footage obtained from concealed cameras in the workplace.

The employees worked as supermarket cashiers. An investigation was launched after significant stock discrepancies were identified, which included installing both visible and concealed cameras. Notices were put up in the supermarket to inform customers and staff that CCTV was being used, but staff were not told about the concealed cameras.

The covert CCTV helped identify the five cashiers who were involved in the thefts and all were dismissed. Their unfair dismissal claims were not upheld by the Spanish courts, which held that the covert CCTV footage had been lawfully obtained. Although employees were not told about the concealed cameras (for obvious reasons), the surveillance was justified based on the employer’s reasonable suspicion of theft and because on the facts, the use of the concealed cameras was deemed a necessary and proportionate means of identifying the perpetrators behind the thefts.

In finding that there was no Article 8 violation, the European Court noted that the employees had a limited right to privacy on the shop floor, the concealed CCTV had been used for a short duration and for a specific purpose, access to the footage had been restricted, and that telling staff about the concealed cameras would have jeopardised the investigation. Accordingly, the Spanish courts had acted within their margin of appreciation in holding the use of the cameras had been proportionate and that the dismissals were fair.

Why this matters

This decision recognises the margin of appreciation afforded to States when applying ECHR principles to private bodies under national law. There will be cases where the use of covert monitoring is appropriate, but UK employers should not read this case as giving them carte blanche to monitor in whatever way they see fit – if monitoring is necessary, it should generally be carried out in the least intrusive manner possible and be targeted at a specific area of risk.

López Ribalda and others v Spain


Anti-gay remarks made by lawyer on radio show could be actionable as unlawful discrimination

The Advocate General has opined that remarks made by a lawyer on an Italian radio show in which he said he would not hire a homosexual person could be unlawful discrimination.

The case was referred to the ECJ by the Italian Supreme Court, after the lower courts in Italy had upheld a discrimination claim brought by an association for LGBT lawyers.

At the time the remarks were made, the law firm in question had not been not actively recruiting. However, the Advocate General said that this did not mean the remarks were not still capable of hindering access to employment. Whether or not this was the case was for the national court to determine, and relevant factors to take into account included the status of the person making the remarks and to what extent they could be said to discourage persons belonging to the protected group from applying for employment.

Why this matters

We now wait for the ECJ’s decision in this case, although it is common for the ECJ to follow the Advocate General’s opinion. As it stands, this is an important reminder that the absence of an immediately identifiable ‘victim’ of the remarks does not mean they are not still potentially actionable, if in all of the circumstances the conduct would deter individuals from the protected group from applying for employment.

NH v Associazione Avvocatura per i diritti LGBTI-Rete Lenford


Interim injunction refused under the Protection from Harassment Act 1997

The High Court has refused to grant an injunction to prevent alleged harassment under the Protection from Harassment Act 1997 (PHA).

The injunction was sought by a male school teacher, following an article which was published on a women’s organisation website titled “Indian Bride, used, abused and discarded by East London school teacher”. The article had been written by a journalist and women’s rights campaigner and purported to give Mr Jagwani’s ex-wife’s account of their marriage and separation. The article was republished on various websites and also shared on social media.

Mr Jagwani also complained that he had been contacted by the author by telephone and text message, that various untrue and defamatory statements about him had appeared on social media and that violence had been incited against him with the use of the hashtag #JustWaitWeAreComingForYou (taken from The Handmaid’s Tale).

The High Court was satisfied that Mr Jagwani had been distressed by these events and his health had been impacted. However, the court was not satisfied that the conduct in question was sufficiently serious to justify an injunction. He had only been contacted once by telephone and text, which was not the ‘course of conduct’ required under the PHA. As to the article and social media comments, there was no exceptional circumstance which justified any restriction on the author’s freedom of expression. Finally, the hashtag could not be viewed as a serious incitement of violence against Mr Jagwani, since it made no reference to him.

Why this matters

This case is a useful reminder of the relatively high threshold for harassment under the PHA. In particular, there must be a ‘course of conduct’ (i.e. at least two occasions), which is oppressive and unreasonable and targeted to cause alarm or distress. This is in contrast to harassment based on a protected characteristic under the Equality Act, which can be a one-off incident.

Jagwani v Alles


British civilians employed by US Government in the UK could not bring UK Employment Tribunal claims

The Employment Tribunal has declined to hear claims from two British civilians who were employed by and worked in the UK for the US Air Force. The Tribunal held that the doctrine of state immunity applied and that to have considered the merits of the claims would have been to adjudicate on the sovereign acts of a foreign state, which was not permissible.

The US Air Force Europe (a division of the US Air Force) operated from various RAF bases in the UK as part of long-standing military co-operation between the two countries. The claimants were employed as local civilian personnel – one in records management and the other as a firefighter. Both claimants brought claims in the UK Employment Tribunal for unfair dismissal and discrimination. The UK Air Force disputed the Tribunal’s jurisdiction to hear the claims based on state immunity, without commenting on the merits of the claims.

At a preliminary hearing, the Employment Judge held that the correct respondent was the United States (not the US Air Force Europe or US Air Force as neither had any separate legal personality distinct from the state) and further that the United States had the benefit of state immunity. As a matter of fact, the Tribunal found that both claimants were involved in governmental functions and therefore common law state immunity applied. Further, that the United States could not be said to have submitted to the jurisdiction since they had taken no steps in the proceedings other than to claim immunity.

Why this matters

The doctrine of state immunity has received increased attention recently, including following the death of Harry Dunn in a traffic collision near RAF Croughton. There is a feeling that it can lead to apparent injustices, as noted by the Employment Judge in this case when he expressed his personal sympathy with the claimants. However, it is important to note that all cases involving foreign states will turn on their facts, including whether or not the employees in question are truly engaged in a governmental function such that the immunity applies.

Webster and another v United States of America


‘Likely to succeed’ test applies to all elements of the Claimant’s claim where interim relief is sought in a whistleblowing claim

The EAT has held that a claimant who makes an application for interim relief in an unfair dismissal case, must satisfy the Tribunal that their claim is ‘likely to succeed’ in all respects.

Interim relief is a remedy available in certain types of unfair dismissal claims, including whistleblowing cases. If granted, it requires the employer to continue to employ (and pay) the employee until final determination of the claim at trial. The test which the Tribunal must apply in determining the application is whether the claim is ‘likely to succeed’ at trial.

In this case, unfair dismissal claim was brought by a dentist whose agreement with the dental practice in which he worked had been terminated, allegedly after he raised concerns about the fitness to practice of another dentist. As well as issuing his substantive claim, he also made an application for interim relief.

There was a question mark over the dentist’s employment status. The agreement between the dentist and the dental practice stated that it was not a contract of employment, albeit the nature of the working relationship had many features of a traditional employer/employee relationship.

The Tribunal granted the interim relief application without first holding a preliminary hearing to determine the question of the dentist’s employment status. The Tribunal held that the interim relief application was by its nature an assessment of whether the claimant was likely to succeed at trial, including an assessment of whether the claimant was likely to succeed on the issue of employment status. In this case the Tribunal was satisfied that on the facts the issue of employment status was likely to be resolved in the claimant’s favour and that as a whole the claim was ‘likely to succeed’ at trial.

The claimant appealed the Tribunal’s decision. However, his appeal was dismissed by the EAT which endorsed the approach the Tribunal had taken.

Why this matters

This is helpful clarification of the hurdles which a claimant must overcome in making an interim relief application. Whilst interim relief applications remain relatively uncommon, an employer who finds themselves on the receiving end should ensure that they are sufficiently prepared to challenge all aspects of the claimant’s claim at this early stage, including any jurisdictional issues which may arise on the facts.

Hancock v Ter-Berg and another


Holiday carry over can be limited to four weeks in sickness absence cases

In a referral from the Finnish Labour Court, the ECJ has confirmed that it is permissible for Member States to impose a 4 week limit on the amount of holiday that can be carried over from one leave year to the next in cases where a worker is prevented from taking all of their leave in the relevant year due to ill-health. This is notwithstanding that the Member State may provide for a more generous holiday entitlement under national law than the four weeks provided for under the Working Time Directive.

Why this matters

Helpfully, this decision confirms the approach taken by the EAT in Sood Enterprises Ltd v Healy. In Sood, the EAT held that there was no requirement to allow a worker who was prevented from taking holiday due to ill-health to carry over the full 5.6 weeks’ holiday granted under the Working Time Regulations (which implements the Working Time Directive in the UK). Employers can therefore continue to limit carry over of holiday in sickness absence cases to the four weeks’ leave under the Directive, with the comfort that there is now also ECJ authority on the point.

Terveys-ja sosiaalialan neuvottelujarjesto (TSN) ry v Hyvinvointialan liitto ry


Roundup of other developments

Government responds to Women and Equalities Committee report on NDAs in discrimination cases

In the Government response to the Women and Equalities Committee report on the use of NDAs in cases involving discrimination and harassment, the Government has confirmed that it intends to introduce legislation in this area, including limiting the use of confidentiality clauses in employment contracts and settlement agreements. However, some of the more radical recommendations in the Committee’s report will not be adopted, and others will considered by the Government further.

Government publishes independent review into the international evidence on minimum wages

The Government has published the findings of the review undertaken by Professor Arindrajit Dube into international evidence on the impact of minimum wages. The review concludes that minimum wages in a number of countries have had a minimal impact on jobs but have increased the earnings of the lowest paid workers. The review was commissioned by the Conservative Government in order to inform policy on the minimum wage, with the current Chancellor announcing plans to increase the National Living Wage (‘NLW’) to £10.50 an hour by 2024 and to reduce the threshold for the NLW from age 25  to 21.

Legal challenge to Government’s alleged digital discrimination of visa applications

The Home Office is facing a legal challenge from the Joint Council for the Welfare of Immigrants (‘JCIW’) which alleges that its software is creating a ‘digital hostile environment’ for immigrants, with an algorithm that allegedly discriminates based on characteristics such as nationality or age. The JCIW is seeking clarity over how the technology is used. The Home Office is defending the legal challenge and maintains that the technology is intended to improve efficiency, that it fully complies with equality legislation and that caseworkers ultimately decide the outcome of all visa applications.

ICO guidance on special category data

The ICO has published guidance on special category data, highlighting the importance of identifying such data and handling it carefully. The guidance is aimed at individuals within larger organisations who have responsibility for data protection.

[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.

© Bryan Cave Leighton Paisner | Attorney Advertising

Written by:

Bryan Cave Leighton Paisner
Contact
more
less

Bryan Cave Leighton Paisner 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.