XAI: Explainable AI – Data Protection Hobbling the Prediction Machine?

White & Case LLP

White & Case LLPOn 2 December 2019, the UK Information Commissioner's Office ("ICO") together with The Alan Turing Institute published1 a three-part consultation (with draft guidance) on explaining decisions made with Artificial Intelligence ("AI"), badged "Project ExplAIn". Part 1 is aimed at all staff involved in developing AI systems, including Compliance and the Data Protection Officer ("DPO"), and sets out the basics of explainability concepts. Part 2 sets out the practicalities of providing explanations of AI to individuals, and Part 3 focuses on the roles, policies, procedures and documentation necessary to ensure a business can provide meaningful explanations to affected individuals.


The "Project ExplAIn" consultation was issued in response to the commitment in the UK Government's April 2018 AI Sector Deal to boost the UK's global position as a leader in developing AI technologies. This is not a statutory code of practice under the Data Protection Act 2018. Rather, the consultation comprises draft practical guidance on good practice for explaining data processing decisions made using AI systems to affected individuals. It clarifies the application of data protection law relevant to explaining AI decisions and identifies other relevant legal regimes outside the ICO's remit. Responses are due by 24 January 2020.

XAI Legal Framework


The use of personal data to train, test or deploy an AI system falls within the scope of the General Data Protection Regulation ("GDPR") and the Data Protection Act 2018 ("DPA 2018"), which regulate the processing of personal data. Both the GDPR and the DPA 2018 include provisions specific to large scale automated processing of personal data, profiling and automated decision-making, and as such, directly govern the use of AI to provide a prediction or recommendation about individuals.

Any business seeking to comply with the GDPR and the DPA 2018, must be able to provide individuals with a meaningful explanation of its fully automated decisions that involve the processing of personal data. This facilitates the exercise of an individual's rights under data protection law, including the right of access, and the right to object and the right to obtain meaningful information, express their point of view, and contest fully automated decisions. Where a decision affecting an individual involves the processing of personal data and the use of AI (whether or not augmented with meaningful human involvement) the principles set out in the GDPR are relevant – especially those of fairness, transparency and accountability.

  • Articles 13-14 of the GDPR require that businesses proactively provide individuals with "…meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject…" in the case of solely automated decisions with a legal or similarly significant effect.
  • Article 15 of the GDPR also gives individuals a right to obtain this information at any time on request.

Even where decision making systems are not fully automated, and there is a "human in the loop", the ICO recommends that these principles should be followed as good practice.

Equality Act and Administrative law

The Equality Act 2010 applies to those businesses using AI in their decision-making process, who must show that this does not result in discrimination. Judicial review under administrative law is also available as a means of challenging decisions made by the public sector or by private sector entities contracted by government to carry out public functions which deploy AI to support decision-making, on the basis that the decision was illegal or irrational, or the way in which it was made was "improper".

XAI Explanation types and Principles

The ICO identifies six primary explanation types:

  1. Rationale explanation: the reasons that led to a decision, delivered in an accessible and non-technical way, which also assists businesses with GDPR compliance;
  2. Responsibility explanation: who is involved in the development, management and implementation of an AI system, and who to contact for a human review of a decision;
  3. Data explanation: what data have been used in a particular decision and how; what data have been used to train and test the AI model and how;
  4. Fairness explanation: steps taken across the design and implementation of an AI system to ensure that the decisions it supports are generally unbiased and fair, and whether or not an individual has been treated equitably;
  5. Safety and performance explanation: steps taken across the design and implementation of an AI system to maximise the accuracy, reliability, security and robustness of its decisions and behaviours; and
  6. Impact explanation: the impact that the use of an AI system and its decisions has or may have on an individual, and on wider society.

The ICO also specifies four principles which businesses should follow:

  1. Be transparent: render the technical rationale underlying the model's output comprehensible and give plain-language reasons which affected individuals can easily evaluate;
  2. Be accountable: consider accountability at each stage of the AI system's design and deployment and whether design and implementation processes been made traceable and auditable across the entire project;
  3. Consider the context in which the business operates; and
  4. Reflect on the impact of the business's AI on the individuals affected, as well as on wider society, e.g. whether the model has been designed, verified and validated to ensure it is secure, accurate, reliable and robust.

XAI Organisational Functions and Policies

The ICO requires all those involved in a business's decision-making pipeline to participate in providing an explanation of a decision supported by an AI model's result. Under data protection law, controllers are responsible for ensuring that any AI system whose development is outsourced is explainable.

Key areas to cover in businesses' policies and procedures are set out, including documenting both the processes behind the design and implementation of the AI system and the actual explanation of its outcome.

Where opaque algorithmic techniques, whose inner workings and rationale are inaccessible to human understanding (such as black box AI) are used, businesses must identify the ancillary risks, show how these risks are mitigated via supplementary explanatory algorithms or other tools, and provide evidence of any determination that their use case and organisational capacities support the system's responsible design and implementation. Businesses must also show that any potential for biases in the model design are assessed, monitored and mitigated.

XAI in practice

The ICO's draft guidance sets out the practicalities of explaining AI-assisted decisions and providing explanations to individuals, including how to choose a sector and use case-appropriate explanations and tools for extracting explanations from less interpretable models.

The ICO also provides technical teams with a comprehensive guide to choosing appropriately interpretable models and supplementary tools to render opaque black box AI determinations explainable. Further resources for exploring XAI are listed in the Appendix to the draft guidance.

The ICO's suggested steps include the following:

  1. Select priority explanations by considering the domain, use case and impact on the individual;
  2. Collect the information required for each explanation type;
  3. Build a rationale explanation to provide meaningful information about the AI system's underlying logic;
  4. Translate the rationale of the AI system's results into usable and easily understandable reasons;
  5. Prepare implementers to deploy the AI system;
  6. Consider contextual factors when delivering the explanation; and
  7. Consider how to present the explanation.

The draft guidance divides each type of explanation into two categories:

  1. Process-based explanations of AI systems, which show that good governance processes and best practices have been followed throughout design and use;
  2. Outcome-based explanations of AI systems, which clarify the results of a particular algorithmically generated result in plain language. Affected individuals must also be shown how and why a human judgment augmented by AI output was reached.

Appropriately explainable models should factor-in cases where social or demographic data are being processed, which may involve particular issues of bias and discrimination, and thus drive the choice of an optimally interpretable model, avoiding black box AI. These techniques may include decision trees or rule lists, linear regression and generalised additive models, case-based reasoning, or logistic regression.

Opaque black box AI and supplementary algorithms which can explain it

The ICO warns that black box AI systems, including neural networks and random forests, should only be used where their potential impacts and risks have been thoroughly considered. A business's use case and organisational capacities must support the responsible design and implementation of black box AI, and any supplemental interpretability tools should provide the system with sufficient explainability to mitigate the identified risks and give affected decision recipients meaningful information about the rationale of any outcome.

Helpfully, the ICO sets out a detailed list of the supplementary techniques which can provide some access to the underlying logic of black box AI models. The ICO's research has shown that, while the banking and insurance sectors are continuing to select interpretable models in their customer-facing AI decision-support applications, they are increasingly using more opaque black box "challenger" models alongside these for the purposes of benchmarking, comparison and insight. The ICO notes that, where challenger models are used to process the personal data of affected decision recipients even for benchmarking purposes, they should be properly recorded and documented.

The ICO guidance includes a table listing the basic properties, potential uses and interpretability characteristics of the currently most widely used algorithms, of which, the first 11 are considered to be mostly interpretable, and the final four to be primarily black box algorithms. The AI systems listed by the ICO mostly produce statistical outputs based on correlation rather than causation, so businesses are warned to sensecheck whether the correlations produced by the AI model make sense for each relevant use case.

Peeking into the black box: local vs global and intrinsic vs external explanations

The draft guidance draws a distinction between the explanation of single instances of an AI model's results (a "local explanation" aiming to interpret individual predictions or classifications) and that of how it works across all its outputs (a "global explanation" capturing the inner logic of that model's behaviour across predictions or classifications).

The ICO also notes that applying an internal or model-intrinsic explanation to black box AI can shed light on that opaque model's operation by breaking it down into more understandable, analysable and digestible parts. For example, in the case of an artificial neural network (ANN) it can break it down into interpretable characteristics of its vectors, features, interactions, layers and parameters (often referred to as "peeking into the black box").

By contrast, external or post-hoc explanations are more applicable to black box systems where it is not possible to access fully the internal underlying rationale due to the model's complexity. These attempt to capture essential attributes of the observable behaviour of a black box system by reverse-engineering explanatory insights.

Sense-check the statistical rationale

Understanding the correlations or statistical rationale between input variables and an AI model's result is described in the draft guidance as the first step in moving from the model's mathematical inferences to a meaningful explanation. But, as the ICO notes, "correlation does not imply causation" and the guidance requires additional steps to assess the role that these statistical associations should play in a reasonable explanation, given the specific context.

Train humans to deploy AI non-anthropomorphically

Where decisions are human-augmented rather than fully automated, human implementers must be appropriately trained to use the model's results responsibly and fairly, including on the basics of how machine learning works, the limitations of AI and automated decision-support technologies and the benefits and risks of deploying these systems (especially how they augment, rather than replace, human judgment). Training must highlight the risks of cognitive biases, such as overconfidence in a prediction based on the historical consistency of data, or illusions that any clustering of data points necessarily indicates significant insights. The ICO warns that any training should avoid anthropomorphic portrayals of AI systems.

Where decisions are fully automated and provide a result directly to the decision recipient, businesses should set up the AI system to provide understandable explanations.

What does this mean for market participants?

The ICO warns that businesses that do not explain AI-assisted decisions could face regulatory action, reputational damage and disengagement by the public. The ICO notes that process-based and outcomebased explanations relating to the rationale of an AI system, and an outcome-based explanation relating to the AI system's impact on the individual, can fulfil the requirements in Articles 13-15 of the GDPR – but that it is up to each business to determine the most appropriate way to deliver the explanations which that business elects to provide.

The regulator is also aware, however, that businesses may need to protect against the risk of third parties gaming an AI model if they know too much about the reasons underlying its decisions. It is therefore essential for businesses that are using AI for data processing purposes to find an appropriate balance that provides individuals with an explanation of how their data will be processed, without exposing the AI systems to the risk of attack by malicious third parties.

Click here to download 'XAI: Explainable AI – Data Protection Hobbling the Prediction Machine?' PDF

1 https://ico.org.uk/about-the-ico/ico-and-stakeholder-consultations/ico-and-the-turing-consultation-on-explaining-ai-decisions-guidance/ The UK Financial Conduct Authority (FCA) is also working with The Alan Turing Institute on AI explainability for financial services firms, having highlighted the explainability of decisions made on the basis of black box algorithms and data privacy in its April 2019 Research Agenda at https://www.fca.org.uk/publication/corporate/fca-research-agenda.pdf. An FCA speech this summer at https://www.fca.org.uk/news/speeches/future-regulation-ai-consumer-good noted that the FCA and the Institute will be undertaking a joint publication on AI explainability, with a workshop planned for early 2020.

[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.

© White & Case LLP | Attorney Advertising

Written by:

White & Case LLP

White & Case 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.